Free Motion to Withdraw - District Court of Colorado - Colorado

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

Document 89

Filed 12/14/2005

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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 FOR WITHDRAWAL OF COUNSEL _______________________________________________________________________________ Defendants, through their counsel, Geoffrey S. Race of the law firm of Wells, Anderson & Race LLC, moves for an Order of this Court permitting the withdrawal of Greg W. LePage and Timothy R. Pitner as counsel for the defendants. In support hereof, defendants represent to the Court as follows: 1. The undersigned counsel has discussed this Motion with Donald Lawrence, Jr., one

of the counsel for the plaintiffs. He has no objection to the granting of this Motion. 2. Greg W. LePage is no longer associated with Wells, Anderson & Race LLC. His

whereabouts are unknown to the undersigned. It is believed that he is no longer practicing law in the State of Colorado. 3. Effective December 15, 2005, Timothy R. Pitner will no longer be associated with

Wells, Anderson & Race LLC. Mr. Pitner will pursue other career opportunities.

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

Document 89

Filed 12/14/2005

Page 2 of 3

4.

Other counsel are presently representing the defendants and, therefore, the defendants

will remain represented by counsel after the withdrawal of Greg W. LePage and Timothy R. Pitner. WHEREFORE, Defendants pray for an Order permitting the withdrawal of Greg W. LePage and Timothy R. Pitner as counsel for Defendants in this litigation. Dated this 14th day of December, 2005. 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 89

Filed 12/14/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 14th day of December, 2005, I electronically filed the foregoing MOTION FOR WITHDRAWAL OF COUNSEL with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail 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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