Free Motion to Withdraw - District Court of Colorado - Colorado

Case 1:00-cv-01000-JLK-BNB

Document 133

Filed 08/23/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 00-cv-1000 RAS HOLDING CORP., a Delaware Corporation, et. al., Plaintiffs, v. DR. HOWARD N. STRAUB, a Colorado resident, et. al., Defendants.

MOTION TO WITHDRAW Comes now the law firm of Isaacson Rosenbaum, P.C., as counsel of record for Dr. Howard N. Straub, and requests this Honorable Court enter an Order allowing him and the firm to withdraw for this administratively closed case, and as grounds therefor, states as follows: 1. 2. The case has been administratively closed. Previous co-counsel who had extensive patent experience has withdrawn from

representation of the Defendants in this matter. 3. Present counsel does not have sufficient wherewithal to carry on in the

representation of the Defendants in light of the absence of the patent co-counsel. 4. Counsel has conferred with his client and has advised his client of this Motion and

Defendant has no objection to this request to withdraw. 5. Counsel has made a good-faith effort to resolve the differences between the

parties and has been unsuccessful.

Case 1:00-cv-01000-JLK-BNB

Document 133

Filed 08/23/2007

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6.

In light of the present posture of the case, the Defendant will have adequate time

to secure appropriate counsel if necessary. 7. Counsel cannot serve in a meaningful and knowledgeable capacity in light of the

present posture of representation in this case. 8. Pursuant to D.C.COLO.LCivR 7.1, undersigned counsel has conferred with Texas

counsel for the Plaintiffs. Counsel for the Plaintiffs are objecting to said withdrawal unless new counsel enters an appearance. WHEREFORE, counsel respectfully requests that this Honorable Court grant his Motion to Withdraw for the above stated reasons. Respectfully submitted this 23rd day of August, 2007.

BY: s/ Gary Lozow________________ GARY LOZOW ISAACSON ROSENBAUM, P.C. 633 17th Street, Suite 2200 Denver, CO 80202 Phone: 303-292-5656 Fax: 303-292-3152 ATTORNEYS FOR DEFENDANTS DR. HOWARD N. STRAUB, et.al

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Case 1:00-cv-01000-JLK-BNB

Document 133

Filed 08/23/2007

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CERTIFICATE OF SERVICE I hereby certify that on August 23rd, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to all counsel of record. s/ Gary Lozow Gary Lozow

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