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

Case 1:03-cv-02328-RPM-CBS

Document 50

Filed 09/23/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2328-RPM-OES GREG JOSEPH GONZALES, by and through his next friend, JUNE BRAVO Plaintiffs, v.

OFFICER BRETT C. TITUS, in his official and personal capacity, and CITY AND COUNTY OF DENVER, Defendants. ______________________________________________________________________________ MOTION TO WITHDRAW AS COUNSEL ______________________________________________________________________________ BENJAMIN P. ECKHART, co-counsel of record for Defendant, BRETT C. TITUS, pursuant to D.C.COLO.LCivR 83.3(D), hereby moves to withdraw as counsel in this matter. AS GROUNDS THEREFOR, counsel states: 1. Mr. Eckhart is currently an associate attorney with Senter Goldfarb & Rice,

L.L.C. Mr. Eckhart will be terminating his employment with Senter Goldfarb & Rice, L.L.C., effective September 23, 2005. As a result, good cause exists to allow Mr. Eckhart to withdraw as counsel in this case. 2. Defendant will continue to be represented by Eric M. Ziporin 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. Eckhart.

Case 1:03-cv-02328-RPM-CBS

Document 50

Filed 09/23/2005

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3.

Pursuant to D.C.COLO.LCivR 83.3(D), a copy of this motion is being served on

Defendant, by his attorneys, ERIC M. ZIPORIN and BENJAMIN P. ECKHART of the law firm SENTER GOLDFARB & RICE, L.L.C., by U.S. Mail. WHEREFORE, the undersigned requests that the Court find that good cause exists to allow Mr. Eckhart to withdraw as counsel in this matter and enter an Order allowing Mr. Eckhart to withdraw his appearance as counsel of record. Respectfully submitted, SENTER GOLDFARB & RICE, L.L.C.

/s Benjamin P. Eckhart Benjamin P. Eckhart 1700 Broadway, Suite 1700 Denver, Colorado 80290 Telephone: (303) 320-0509 Facsimile: (303) 320-0210 E-Mail: [email protected] Attorney for Defendant

Case 1:03-cv-02328-RPM-CBS

Document 50

Filed 09/23/2005

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 23rd day of September, 2005, a true and correct copy of the above and foregoing MOTION TO WITHDRAW AS COUNSEL was placed in the U.S. Mail, first class postage pre-paid, addressed to: Brian DeBauche, Esq. Brian DeBauche & Associates, L.L.C. 401 Kalamath Street Denver, CO 80204 David Bruno, Esq. Bruno, Bruno & Colin, P.C. 1560 Broadway, Ste. 1099 Denver, CO 80202-5143 Thomas Bigler Assistant City Attorney Office of the City Attorney 201 W. Colfax Ave., Dept. 1108 Denver, CO 80202 s/ Stephanie Nelson Stephanie Nelson E-mail: [email protected] Secretary for Attorney Benjamin P. Eckhart

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