Free Motion for Leave - District Court of Colorado - Colorado

Case 1:04-cv-01002-MSK-CBS

Document 252

Filed 07/06/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO 04-cv -1002- MK-CBS Donja Vaughn, Plaintiff v. Simms Rhea, et al. Defendants : : : : : :

REVISED UNOPPOSED MOTION FOR LEAVE TO APPEAR AT JULY 10, 2006 HEARING BY PHONE Plaintiff, by and through her counsel, avers as follows: 1. On June 29, 2006 the court entered an order vacating the trial date of July 10, 2006 and setting a hearing at 9:30 a.m. that day. 2. Plaintiff's counsel has offices in West Chester, Pa and Durango, CO. It involves substantial cost and expenditure by Plaintiff, incarcerated and without income and with few assets, to pay for her counsel to travel to Denver. The hearing will likely not take more than an hour. 3. Defense counsel Jack Robinson and Kathleen Spalding do not oppose the relief sought. WHEREFORE, Plaintiff seeks relief in the form of the attached order. Date: June 30, 2006 s/ J. Michael Considine, Jr. J. Michael Considine, Jr. CO Reg. No. 029253 12 East Barnard Street, Suite 100 West Chester, PA 19382 (610)431-3288 Counsel for Plaintiff

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Case 1:04-cv-01002-MSK-CBS

Document 252

Filed 07/06/2006

Page 2 of 2

CERTIFICATE OF COMPLIANCE In conformance with F.R.C.P. 26 (c) and D. Colorado L. Civ. 7.1.A., the undersigned certifies that he conferred with defense counsel on June 29, 2006 in a good faith effort to resolve this matter without court action. Counsel for Defendants Rhea, Shoun and Stevenson do not oppose the relief sought. Because Defendants Olt and Conner have settled with Plaintiff, their counsel was not contacted. Date: June 30, 2006 s/ J. Michael Considine, Jr. J. Michael Considine, Jr.

CERTIFICATE OF SERVICE I, J. Michael Considine, Jr., hereby certify that I electronically filed a true and correct copy UNOPPOSED MOTION FOR LEAVE TO APPEAR AT JULY 10, 2006 HEARING BY PHONE to the following counsel of record on the date indicated below: Kathleen L. Spalding, Asst. Attorney General, State Services Building, 1525 Sherman Street, 5th Floor, Denver, CO 80202, and Jack B. Robinson, Spies, Powers & Robinson, P.C., 1660 Lincoln Street, Suite 2220, Denver, CO 80264 Date: June 30, 2006 s/ J. Michael Considine, Jr. J. Michael Considine, Jr.

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