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

Case 1:04-cv-00051-REB-CBS

Document 99

Filed 06/08/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-CV-0051-REB-CBS SCOTT A. CUNNINGHAM Plaintiff, v. BHP BILLITON PETROLEUM GREAT BRITAIN, a United Kingdom private limited company, BHP PETROLEUM GREAT BRITAIN PLC, a United Kingdom public limited company BHP PETROLEUM (U.K.) CORPORATION, a Delaware Corporation, and HAMILTON BROTHERS PETROLEUM CORPORATION, a Delaware corporation, Defendants. MOTION TO WITHDRAW ERIC B. LIEBMAN AS ATTORNEY OF RECORD FOR PLAINTIFF SCOTT A. CUNNINGHAM The undersigned hereby respectfully requests that this Court enter an Order removing Eric B. Liebman from the Court's records and ECF notifications as attorney of record for Plaintiff Scott A. Cunningham. 1. Eric B. Liebman, formerly with the firm of Lindquist & Vennum P.L.L.P. had

entered his appearance on behalf of Plaintiff Scott A. Cunningham. 2. Eric B Liebman terminated his employment with Lindquist & Vennum P.L.L.P.

on March 29, 2006, and no longer represents the Plaintiff.

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Case 1:04-cv-00051-REB-CBS

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3.

Plaintiff Scott A. Cunningham will continue to be represented by Charles F.

Brega and Stuart N. Bennett of the firm of Lindquist & Vennum P.L.L.P. 4. Good cause exists for the withdrawal of Eric B. Liebman as counsel for Plaintiff,

and withdrawal will not prejudice any of the parties in this action. 5. The undersigned further certifies that a copy of this Motion has been served upon

Plaintiff Scott A. Cunningham. Dated: June 8, 2006 s/ Stuart N. Bennett Stuart N. Bennett Attorneys for Plaintiffs Lindquist & Vennum P.L.L.P. 600 ­ 17th Street, Suite 1800 South Denver, CO 80202 Tel: 303-573-5900 Fax: 303-573-1956 E-mail: [email protected]

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Case 1:04-cv-00051-REB-CBS

Document 99

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CERTIFICATE OF SERVICE I hereby certify that on June 8, 2006, I submitted the foregoing to the Clerk of Court for filing on the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected] Eric B. Liebman, Esq. Moye White LLP 16 Market Square, 6th Floor 1400 ­ 16th Street Denver, CO 80202 Frank C. Porada, Esq. Featherstone DeSisto LLP 600 ­ 17th Streee, Suite 1300 Denver, CO 80202 Attorneys for Defendants

[email protected]

and I hereby certify that I have mailed or served the document or paper to the following nonparticipants in the manner indicated by the non-participant's name: NONE. I also certify that on June 8, 2006, a true and correct copy of the foregoing was sent by United States mail, first-class postage prepaid, addressed to: Mr. Scott Cunningham 4215 S. Dahlia Street Englewood, CO 80113-5003 s/ Stuart N. Bennett Stuart N. Bennett Attorneys for Plaintiffs Lindquist & Vennum P.L.L.P. 600 ­ 17th Street, Suite 1800 South Denver, CO 80202 Tel: 303-573-5900 Fax: 303-573-1956 E-mail: [email protected] 3
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