Free Certificate of Compliance - District Court of Colorado - Colorado

Case 1:03-cv-02633-PSF-PAC

Document 304

Filed 12/20/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02633-PSF-PAC LILLIAN BARTON, Plaintiff, v. OFFICER R. BLEY, Badge No. 99006 OFFICER N. SAGEN, Badge No. 96-021 OFFICER JOHN DOE Defendants. and Civil Action No. 04-cv-319-PSF-PAC LILLIAN BARTON, Plaintiff, v. RICHARD BLEA NICK SAGAN JOSH VASCONCELLOS Defendants. ______________________________________________________________________________ CERTIFICATE OF COMPLIANCE PURSUANT TO D.C.COLO.LCivR 54.1 ______________________________________________________________________________ Defendants, OFFICER RICHARD BLEA (incorrectly designated as "Bley"), OFFICER NICK SAGAN (incorrectly designated as "Sagen"), and OFFICER JOSH VASCONCELLOS (hereinafter "Defendants"), by their attorneys, SONJA S. McKENZIE and BRETT A. McDANIEL of SENTER GOLDFARB & RICE, L.L.C., hereby file their Certificate of Compliance pursuant to D.C.Colo.L.CivR 54:

Case 1:03-cv-02633-PSF-PAC

Document 304

Filed 12/20/2006

Page 2 of 3

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Undersigned counsel has inquired as to Plaintiff' position regarding those costs s

requested pursuant to Defendants'Bill of Costs filed on December 6, 2006. 2. Defendants have been informed that Plaintiff' counsel, Mr. A. Thomas Elliott, s

Jr., has no authority to stipulate or otherwise discuss those costs requested by Defendants as Mr. Elliott has filed a Motion to Withdraw as Counsel of Record for Plaintiff. 3. Mr. Elliott' Motion to Withdraw as Plaintiff' counsel indicates that Plaintiff s s

"agreed with none of what was contained in Defendants'Bill of Costs." An electronic mail from Mr. Elliott on December 13, 2006 also indicates Plaintiff' objection to those costs requested by s Defendants. Since that time, Plaintiff has also filed a pro se objection to Defendants' asserted costs. WHEREFORE, Defendants hereby certify that pursuant to D.C.COLO.LCivR 54.1, a reasonable effort has been made to resolve any dispute regarding costs. However, these efforts have proven to be unsuccessful. Respectfully submitted,

s/ Brett A. McDaniel Sonja S. McKenzie Brett A. McDaniel SENTER GOLDFARB & RICE, L.L.C. 1700 Broadway, Suite 1700 Denver, CO 80290 Telephone: (303) 320-0509 FAX: (303) 320-0210 E-mail: [email protected] [email protected] Attorneys for Defendants Officer Richard Blea, Officer Nick Sagan, and Officer Josh Vasconcellos

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Case 1:03-cv-02633-PSF-PAC

Document 304

Filed 12/20/2006

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 20th day of December, 2006, I electronically filed a true and correct copy of the above and foregoing CERTIFICATE OF COMPLIANCE PURSUANT TO D.C.COLO.LCivR 54.1 with the Court using the CM/ECF system, which will send notification of such filing to the following e-mail address: A. Thomas Elliott, Jr. [email protected] I FURTHER CERTIFY that I have mailed said CERTIFICATE OF COMPLIANCE PURSUANT TO D.C.COLO.LCivR 54.1 to the following non-CM/ECF participant by U.S. Mail, first class postage prepaid: John Eckhardt, Esq. Assistant City Attorney 201 West Colfax Ave., Dept. 1207 Denver, CO 80202-5375

s/ Kathleen Bertz

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