Free Motion to Withdraw - District Court of Colorado - Colorado

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

Document 47

Filed 08/25/2005

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UNITED STATES DISTRICT COURT 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.

UNOPPOSED MOTION TO WITHDRAW

SETH A. RIDER, co-counsel of record for Defendant, BRETT C. TITUS, 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.

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

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Filed 08/25/2005

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3.

Defendant Brett C. Titus will continue to be represented by 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

Brett C. Titus by his 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 Defendant Brett C. Titus 1700 Broadway, Suite 1700 Denver, Colorado 80290 Telephone: (303) 320-0509

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

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Filed 08/25/2005

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CERTIFICATE OF SERVICE 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 with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following: 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/ Marie DeSanto E-mail: [email protected] Secretary for Attorney Seth A. Rider

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