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

Case 1:01-cv-01807-MSK-MJW

Document 424

Filed 04/26/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-cv-01807-MSK-MJW BANK ONE, COLORADO, N.A., BANK ONE TRUST COMPANY, N.A., as Trustee of the Dora Lucille Jamison Trust and the Jamison Family Trust, Plaintiffs, v. BOULDER CLEANERS, Inc., C.V.Y. CORPORATION, d/b/a Your Valet Cleaners, JOHN'S CLEANERS, Inc., Defendants. UNOPPOSED MOTION TO WITHDRAW AS COUNSEL

Pursuant to Local Rule 83.3(D), the undersigned, counsel for Plaintiffs in this action, hereby moves to withdraw as counsel for Plaintiffs in this case. 1. CERTIFICATION PURSUANT TO D.C.Colo. LCivR 7.1(A): The undersigned

counsel hereby certifies that prior to filing this Motion, Plaintiffs' counsel conferred with Defendants' counsel by e-mail on April 21, 2006. On April 24, 2006, opposing counsel informed Plaintiffs' counsel that he consents to the relief requested herein. 2. 3. I am currently listed on the docket as counsel of record for Plaintiffs in this case. Due to the ordinary course of coordinating workloads within my law firm, I no

longer work on this case; rather, my partners Laura Riese and Jonathan Rauchway are the attorneys who are prosecuting this action for the Plaintiffs.

Case 1:01-cv-01807-MSK-MJW

Document 424

Filed 04/26/2006

Page 2 of 3

4.

Our clients, Plaintiffs in this action, are aware that I am no longer working on this

case. Pursuant to Local Rule 83(D), a copy of this Motion has been served on Plaintiffs. 5. The notice provisions of Local Rule 83(D) are inapplicable because Plaintiffs

continue to be represented by other attorneys in my law firm. 6. For the foregoing reasons, good cause exists to grant this Motion, thereby

removing undersigned counsel from the docket as counsel of record and terminating notice of all docket entries to the undersigned counsel. April 26, 2006 Respectfully submitted,

s/ Brett C. Painter Brett C. Painter DAVIS GRAHAM & STUBBS LLP 1550 Seventeenth Street, Suite 500 Denver, Colorado 80202 Telephone: (303) 892-9400 Facsimile: (303) 893-1379 E-mail: [email protected] Attorneys for Plaintiffs

Case 1:01-cv-01807-MSK-MJW

Document 424

Filed 04/26/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on the 26th day of April, 2006, I electronically filed the foregoing UNOPPOSED MOTION TO WITHDRAW AS COUNSEL with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: Gary E. Parish, Esq. Sander Ingebretsen & Parish, P.C. 633 Seventeenth Street, 16th Floor Denver, Colorado 80202 E-mail: [email protected] C. Michael Montgomery, Esq. Max K. Jones, Jr., Esq. Montgomery, Kolodny, Amatuzio & Dusbabek L.L.P. 475 Seventeenth Street, 16th Floor Denver, CO 80202 E-mail: [email protected] The UNOPPOSED MOTION TO WITHDRAW AS COUNSEL was also served (by e-mail) on: Frances L. Figetakis, Esq. JP Morgan Chase Bank, N.A. Mail Code OH1-0152 1111 Polaris Parkway Columbus, OH 43271-0152 Bradley J. Johnson JP Morgan Chase Bank, N.A. Mail Code TX1-2472 1717 Main Street, 9th Floor Dallas, TX 75201

s/ Judy Terranova