Free Motion to Withdraw as Attorney - District Court of Colorado - Colorado

Case 1:04-cv-01099-JLK-DW

Document 101

Filed 10/07/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1099-JLK-DW WOLF CREEK SKI CORPORATION, INC., Plaintiff, vs. LEAVELL-McCOMBS JOINT VENTURE, d/b/a THE VILLAGE at WOLF CREEK, Defendant. JOINT VENTURE'S UNOPPOSED MOTION TO SUBSTITUTE COUNSEL

The Joint Venture respectfully requests that this Court enter the attached proposed Order substituting its counsel in this matter for the following reasons: 1. On September 29, 2005, the Joint Venture retained two additional law firms as

counsel in this matter: Berg Hill Greenleaf & Ruscitti, L.L.P., 1712 Pearl Street, Boulder, Colorado, 80302 (303 402 1600); and Moriarty Leyendecker P.C., 1123 Spruce Street, Suite 200, Boulder, Colorado 80302 (713 528 0700). 2. On September 30, 2005, the Joint Venture informed Magistrate Judge David L.

West that George Berg of the Berg Hill firm would serve as trial counsel with assistance from Jim Moriarty of the Moriarty firm. 3. On October 6, 2005, the Berg Hill firm entered their appearances as counsel of

record. The Moriarty firm will enter its appearance next week. 4. Currently, Holland & Hart LLP is also counsel of record in this matter.

Case 1:04-cv-01099-JLK-DW

Document 101

Filed 10/07/2005

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5.

On October 6, 2005, substitute counsel participated in a telephone hearing with

Magistrate Judge David L. West to set deadlines. In addition, substitute counsel have been provided a complete set of the pleadings and documents served or filed in this matter. 6. Motion. DATED: October 7, 2005 Respectfully submitted, Counsel for the parties have conferred. The Ski Corporation does not oppose this

s/ Joseph T. Jaros Scott S. Barker Joseph T. Jaros HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 P.O. Box 8749 Denver, Colorado 80201-8749 Telephone: 303-295-8000 Fax: 303-295-8261 [email protected] [email protected] ATTORNEYS FOR DEFENDANT LEAVELL-MCCOMBS JOINT VENTURE, D/B/A THE VILLAGE AT WOLF CREEK

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Case 1:04-cv-01099-JLK-DW

Document 101

Filed 10/07/2005

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CERTIFICATE OF SERVICE I hereby certify that on October 7, 2005 I caused to be electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Andrew R. Shoemaker, Esq. Hogan & Hartson L.L.P. 1470 Walnut Street, Suite 200 Boulder, CO 80302 [email protected] George Berg, Esq. Berg Hill Greenleaf & Ruscitti, L.L.P. 1712 Pearl Street Boulder, CO 80302 [email protected] James Moriarty, Esq. (served by electronic mail) Moriarty & Leyendecker P.C. 1123 Spruce Street, Suite 200 Boulder, CO 80302 [email protected] s/ Joseph T. Jaros

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