Free Motion for Leave - District Court of Colorado - Colorado

Case 1:03-cv-01959-MSK-PAC

Document 202

Filed 05/31/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-01959-MSK-PAC AHMED MOHAMMAD AJAJ, Plaintiff, v. ROBERT HOOD, et al., Defendants.

UNOPPOSED MOTION FOR LEAVE PURSUANT TO RULE 30(a)(1) TO TAKE DEPOSITION OF MR. AJAJ

The Defendants, by William J. Leone, United States Attorney, and Elizabeth A. Weishaupl and Amanda Rocque, Assistant United States Attorneys, hereby file the following unopposed motion pursuant to Fed. R. Civ. P. 30(a)(1), for leave to take the deposition of the Plaintiff Ajaj. In support thereto, Defendants state as follows: 1. The Plaintiff Ahmed Ajaj is an inmate in the custody of the Federal Bureau of Prisons incarcerated at the Administrative Maximum (ADX) Facility located in Florence, Colorado. 2. His deposition has been scheduled to take place at the ADX facility on June 15, 2006.

Case 1:03-cv-01959-MSK-PAC

Document 202

Filed 05/31/2006

Page 2 of 3

3.

Leave of Court must be obtained pursuant to Fed. R. Civ. P. 30(a)(1) to permit the deposition of Plaintiff Ajaj as he is "a person . . . confined in prison."

4.

Pursuant to D.C.Colo.LCivR 7.1 undersigned counsel contacted counsel for Plaintiff and she has no objection to this motion.

WHEREFORE, the Defendants respectfully request an order granting leave to take the Deposition of Plaintiff Ajaj. DATED this31st day of May, 2006 WILLIAM J. LEONE United States Attorney

s/ Elizabeth A. Weishaupl Elizabeth A. Weishaupl Amanda Rocque Assistant United States Attorneys 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0109 Facsimile: (303) 454-0404 Email:[email protected] [email protected] Attorneys for Defendants

Case 1:03-cv-01959-MSK-PAC

Document 202

Filed 05/31/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 31st day of May, 2006, I electronically filed the foregoing UNOPPOSED MOTION FOR LEAVE TO TAKE DEPOSITION OF AJAJ with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Carmen Nicole Reilly [email protected] [email protected]

I hereby certify that on this 31st day of May, 2006, I served the foregoing via U.S. mail on the following non-CM/ECF participants: Agency Counsel, as designated agent for and on behalf of individual Defendants: Christopher Synsvoll, Esq. Federal Correctional Complex P.O. Box 8500 5880 Highway 67 South Florence, CO 81226 Email: [email protected]

s/ Elizabeth A. Weishaupl Elizabeth A. Weishaupl Amanda Rocque 1225 Seventeenth Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Facsimile: (303) 454-0404 E-mail: [email protected] [email protected]