Free Motion for Leave to Appear - District Court of Colorado - Colorado

Case 1:04-cv-00779-PSF-BNB

Document 96

Filed 01/10/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00779-PSF-BNB BRITISH AIRWAYS PLC, a foreign corporation, Plaintiff, v. AIRCRAFT SERVICE INTERNATIONAL, INC., a foreign corporation, AIRCRAFT SERVICE INTERNATIONAL GROUP, INC., a foreign corporation; and ASIG HOLDING CORP., a foreign corporation, Defendants. ______________________________________________________________________________ MOTION TO PERMIT APPEARANCE AND ARGUMENT BY TELEPHONE _______________________________________________________________________________ Defendants, through their counsel, Geoffrey S. Race of the law firm of Wells, Anderson & Race LLC, and Charles W. Ryan, III, of the law firm of Dombroff & Gilmore, P.C., move this Court for permission to appear and argue, by telephone, Defendants' Motion for Leave to Designate Additional Non-Parties for Apportionment of Fault Out-of-Time which has been set by this Court for hearing on January 17, 2006, at 3:00 p.m. IN SUPPORT HEREOF, the undersigned represents: 1. Charles W. Ryan, III, of the firm of Dombroff & Gilmore, P.C. is one of the lead

counsel in this matter and is planning to argue Defendants' Motion. 2. 3. Mr. Ryan's offices are in McLean, Virginia. It would be more economical and convenient for Mr. Ryan to appear and argue by

telephone if the Court so permits.

Case 1:04-cv-00779-PSF-BNB

Document 96

Filed 01/10/2006

Page 2 of 3

4.

The undersigned has been advised by Mr. Ryan that counsel for the plaintiff do not

object to Mr. Ryan's appearance and argument by telephone. WHEREFORE, Defendants move this Court for an Order permitting Charles W. Ryan, III, to appear and argue Defendants' Motion for Leave to Designate Additional Non-Party for Apportionment of Fault Out-of-Time by telephone at the hearing set for January 17, 2006. Dated this 10th day of January, 2006. Respectfully submitted, WELLS, ANDERSON & RACE LLC s/ Geoffrey S. Race By ____________________________________ GEOFFREY S. RACE 1700 Broadway, Suite 1020 Denver, Colorado 80290 Telephone 830-1212 [email protected] and DOMBROFF & GILMORE Mark A. Dombroff, Esq. Charles W. Ryan, III, Esq. 1676 International Drive - Penthouse McLean, Virginia 22102 Telephone (703) 336-8800 [email protected] Attorneys for the Defendants

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Case 1:04-cv-00779-PSF-BNB

Document 96

Filed 01/10/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 10th day of January, 2006, I electronically filed the foregoing MOTION TO PERMIT APPEARANCE AND ARGUMENT BY TELEPHONE with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: Amy L. Benson Jeffrey J. Cowman Donald Lawrence, Jr. Charles Warren Ryan, III Diane Westwood Wilson [email protected] [email protected] [email protected] [email protected] [email protected]

s/ Karin Carreaga __________________________________

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