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

Case 1:03-cv-02579-RPM

Document 188

Filed 08/19/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2579-RPM NATIONAL OILWELL VARCO, L.P. Plaintiff, v. PASON SYSTEMS USA CORP., Defendant. UNOPPOSED MOTION FOR AND NOTICE OF WITHDRAWAL OF JOSEPH T. JAROS AS COUNSEL OF RECORD Pursuant to D.C.COLO.LCivR 83.3 D, Plaintiff National Oilwell Varco, L.P., by and through its undersigned attorneys, respectfully requests that the Court enter an order permitting Joseph T. Jaros to withdraw as counsel of record for Plaintiff in this matter for the following reasons: 1. 2008. 2. Plaintiff will continue to be represented by undersigned counsel, Jane Michaels Joseph T. Jaros is no longer associated with Holland & Hart LLP as of May 27,

and Ryan T. Bergsieker of Holland & Hart, Robert M. Bowick of Matthews, Lawson & Bowick, PLLC and John W. Raley, III of Cooper & Scully, P.C. Accordingly, the withdrawal of Mr. Jaros will not in any way delay any aspect of this litigation, or result in prejudice to any party. Pursuant to D.C.COLO.LCivR 7.1A, the undersigned has conferred with counsel for Defendant and is authorized to state that Defendant does not oppose this Motion.

Case 1:03-cv-02579-RPM

Document 188

Filed 08/19/2008

Page 2 of 3

As required by Local Rule 83.3 D, service of this Motion is being made on all counsel of record and on Plaintiff. WHEREFORE, Plaintiff respectfully requests that the Court enter an order permitting Mr. Jaros to withdraw as counsel for Plaintiff in this matter. A proposed form of order is submitted with this Motion for the Court's convenience. DATED: August 19, 2008 s/ Ryan T. Bergsieker Ryan T. Bergsieker Jane Michaels HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Denver, Colorado 80201-8749 Phone: 303-295-8000 Fax: 303-295-8261 Email: [email protected] [email protected] Robert M. Bowick MATTHEWS, LAWSON & BOWICK, PLLC 2000 Bering, Suite 700 Houston, Texas 77057 Phone: 713-755-4200 Fax: 713-355-9689 Email: [email protected] John W. Raley, III COOPER & SCULLY, P.C. 700 Louisiana St., Suite 3850 Houston, Texas 77002 Phone: 713-236-6801 Fax: 713-236-6880 Email: [email protected] ATTORNEYS FOR PLAINTIFF NATIONAL OILWELL VARCO, L.P.

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Case 1:03-cv-02579-RPM

Document 188

Filed 08/19/2008

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on August 19, 2008, I caused to be filed the foregoing with the Clerk of Court using CM/ECF system, which will send notification of such filing to the following email addresses: [email protected] [email protected] [email protected] [email protected]

I additionally certify that on August 19, 2008, I caused to have mailed the foregoing to the following non-CM/ECF participants via U.S. Mail, postage prepaid:

National Oilwell Varco, L.P. Cormac Creaven PO Box 4888 Houston, TX 77210

s/ Ryan T. Bergsieker Ryan T. Bergsieker
3912689_1.DOC

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