Free Motion to Withdraw - District Court of Colorado - Colorado

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

Document 153

Filed 08/25/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2633-PSF-PAC LILLIAN BARTON , Plaintiff, vs. CITY AND COUNTY OF DENVER OFFICER R. BLEY, Badge No. 99006 OFFICER N. SAGEN, Badge No. 96-021 OFFICER JOHN DOE MAYOR JOHN HICKENLOOPER, in his official capacity WELLINGTON WEBB, as former Mayor, in his official capacity GERALD R. WHITMAN, Chief of Police, City and County of Denver, in his office capacity only J. WALLACE WORTHAM, JR., former Denver City Attorney, in his official capacity only CHRIS RAMSEY, former Denver Deputy City Attorney, in his official capacity only Defendants and Case No 04-F-319 (PAC) LILLIAN BARTON, Plaintiff, vs. CITY AND COUNTY OF DENVER RICHARD BLEA NICK SAGAN JOSH VASCONCELLOS MAYOR JOHN HICKENLOOPER WELLINGTON WEBB GERALD R. WHITMAN RUDY SANDOVAL J. WALLACE WORTHAM, JR. CHRIS RAMSEY, Defendants.

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

Document 153

Filed 08/25/2005

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______________________________________________________________________________ UNOPPOSED MOTION TO WITHDRAW ______________________________________________________________________________ SETH A. RIDER, co-counsel of record for Defendants, the CITY AND COUNTY OF DENVER, OFFICER RICHARD BLEA (incorrectly designated as "Bley"), OFFICER NICK SAGAN (incorrectly designated as "Sagen"), OFFICER JOSH VASCONCELLOS, MAYOR JOHN HICKENLOOPER, WELLINGTON WEBB, GERALD R. WHITMAN, RUDY SANDOVAL, J. WALLACE WORTHAM, JR. and CHRIS RAMSEY (hereinafter "Defendants"), by their attorneys, THOMAS S. RICE, ESQ. and SETH A. RIDER, ESQ. of the law firm of SENTER GOLDFARB & RICE, L.L.C., pursuant to D.C.COLO.LCivR 83.3(D), hereby moves to withdraw as counsel in this matter. AS GROUNDS THEREFOR, counsel states: 1. Pursuant to D.C.COLO.LCivR 7.1, the undersigned certifies that he has conferred

with counsel for the other parties in this case, who have confirmed that this motion is unopposed. 2. Mr. Rider is currently an associate attorney with Senter Goldfarb & Rice, L.L.C.

Mr. Rider recently accepted an offer of employment from Baldwin & Carpenter, P.C. and will be terminating his employment with Senter Goldfarb & Rice, L.L.C., effective August 25, 2005. As a result, good cause exists to allow Mr. Rider to withdraw as counsel in this matter. 3. Defendants, Officer Nick Sagan (incorrectly designated as "SAgen"), Officer Josh

Vasconcellos, Mayor John Hickenlooper, Wellington Webb, Gerald R. Whitman, Rudy Sandoval, J. Wallace Wortham, Jr. and Chris Ramsey, will continue to be represented by

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

Document 153

Filed 08/25/2005

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Thomas S. Rice of Senter Goldfarb & Rice, L.L.C., who is co-counsel of record. As a result, Defendant will not be prejudiced by the withdrawal of Mr. Rider from this matter. 4. Pursuant to D.C.COLO.LCivR 83.3(D), a copy of this motion is being served on

the CITY AND COUNTY OF DENVER, OFFICER RICHARD BLEA (incorrectly designated as "Bley"), OFFICER NICK SAGAN (incorrectly designated as "Sagen"), OFFICER JOSH VASCONCELLOS, MAYOR JOHN HICKENLOOPER,

WELLINGTON WEBB, GERALD R. WHITMAN, RUDY SANDOVAL, J. WALLACE WORTHAM, JR. and CHRIS RAMSEY (hereinafter "Defendants"), by their attorneys, THOMAS S. RICE, ESQ. and SETH A. RIDER, ESQ. of the law firm of SENTER GOLDFARB & RICE, L.L.C., Colorado by U.S. Mail. WHEREFORE, the undersigned requests that the Court find that cause exists to allow Mr. Rider to withdraw as counsel on this matter and enter an Order allowing Mr. Rider to withdraw his appearance as counsel of record.

/s/Seth A. Rider Thomas S. Rice Seth A. Rider SENTER GOLDFARB & RICE, L.L.C. Attorneys for Defendants Gerald Whitman, City and County of Denver, Officer Richard Blea, Officer Nick Sagan, Chris Ramsey, Mayor John Hickenlooper, Rudy Sandoval, Wellington Webb, J. Wallace Wortham, Jr. and Officer Josh Vasconsillas 1700 Broadway, Suite 1700 Denver, Colorado 80290 Telephone: (303) 320-0509

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

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Filed 08/25/2005

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CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 25th day of August, 2005, I electronically filed a true and correct copy of the above and foregoing UNOPPOSED MOTION TO WITHDRAW was filed electronically with the Court via PACER and served via the U.S. mail, first class postage prepaid, addressed as follows: Lillian Barton 97 Soda Creek Road Evergreen, CO 80439 _/s/Marie S. DeSanto____ Marie S. DeSanto Legal Secretary to Seth A. Rider [email protected]

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