Free Motion to Withdraw - District Court of Colorado - Colorado

Case 1:04-cv-00617-LTB-BNB

Document 29

Filed 06/30/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00617-LTB-BNB POLYROCK TECHNOLOGIES, LLC, a Colorado limited liability company, Plaintiff, vs. GENERAL STEEL, INC., a Colorado corporation; JEFF KNIGHT; KEVIN KISSIRE; and CHUCK DEMAREST, Defendants. ________________________________________________________________________ MOTION TO WITHDRAW AS COUNSEL ________________________________________________________________________ Fairfield and Woods, P.C., and all attorneys in Fairfield and Woods, P.C. who are of record as counsel for Plaintiff Polyrock Technologies, LLC ("Polyrock") in the above-captioned action, move to withdraw as counsel for Polyrock in the above-captioned action, and as grounds therefor respectfully show: CERTIFICATE OF COMPLIANCE In accordance with D.C.COLO.LCivR 7.1(A), movant counsel, David Stephenson, on behalf of Fairfield and Woods, P.C., and all attorneys in Fairfield and Woods, P.C. of record in this case, has conferred with counsel of record for each party in this case regarding this motion, and the only counsel who objected was Kurt Lewis, counsel for Defendant General Steel, Inc.

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Case 1:04-cv-00617-LTB-BNB

Document 29

Filed 06/30/2005

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Mr. Lewis indicated that his client objects to this motion to withdraw due to the pending Rule 41 motion to dismiss filed by General Steel but, upon inquiry, would not elaborate upon the objection beyond that. 1. On June 20, 2005, John A. DeSisto and W. Curtis Graves of Featherstone DeSisto LLP entered their appearance as counsel for Polyrock. 2. Polyrock is aware of and consents to this motion to withdraw by Fairfield and Woods, P.C. and its attorneys of record in this action. 3. Polyrock does not believe that any party would be prejudiced by granting this motion. 4. Because Polyrock consents to this motion and will continue to be represented by legal counsel in this action if this motion is granted, and no party would be prejudiced by granting this motion to withdraw, the movants request that this court dispense with any additional formalities required for counsel's withdrawal and grant this motion forthwith. WHEREFORE, for the foregoing reasons, Fairfield and Woods, P.C. and its attorneys of record respectfully request that this Court enter an order forthwith granting this motion to withdraw as counsel for Plaintiff Polyrock Technologies, LLC in the above-captioned action.

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Case 1:04-cv-00617-LTB-BNB

Document 29

Filed 06/30/2005

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Respectfully submitted this 30th day of June, 2005.

By:

s/ John M. Tanner John M. Tanner Michael R. McCurdy David J. Stephenson, Jr. Susan B. Fisher Fairfield and Woods, P.C. Wells Fargo Center, Suite 2400 1700 Lincoln Street Denver, Colorado 80203 Phone Number: (303) 830-2400 Fax Number: (303) 830-1033 E-mail: [email protected]

Attorneys for Polyrock Technologies, LLC

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Case 1:04-cv-00617-LTB-BNB

Document 29

Filed 06/30/2005

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that on June 30, 2005, I 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: John A. DeSisto W. Curtis Graves Featherstone DeSisto LLP [email protected] Susan M. Hargleroad Pendleton, Friedberg, Wilson & Hennessey, P.C. [email protected] Kurt S. Lewis Lewis Scheid LLC [email protected] s/ John M. Tanner _______________ John M. Tanner Michael R. McCurdy David J. Stephenson, Jr. Susan B. Fisher Fairfield and Woods, P.C. Wells Fargo Center, Suite 2400 1700 Lincoln Street Denver, Colorado 80203 Phone Number: (303) 830-2400 Fax Number: (303) 830-1033 E-mail: [email protected] Attorneys for Polyrock Technologies, LLC

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