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

Case 1:03-cv-00140-MSK-CBS

Document 123

Filed 07/22/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-00140-MSK-CBS ZEBEDEE E. HALL, Plaintiff, v.

CITY AND COUNTY OF DENVER, THE DENVER SWAT TEAM, [known and unknown] members of, SGT. BERDAHL #86059, TECH. CANINO #91041, TECH. GROTHE #95015, TECH. GILWORTH #89044, TECH. DELMENICO #89029, TECH. FOX #87026, TECH. BRODEN #90026, TECH. MOEN #91027, TECH. LAURTIA #83011, TECH. MCKIHHEN #86042, TECH. TITUS #93013, TECH. MEYER #89041, TECH. BRENNAN #95035, OFC. NEBEL #97015, and SGT. ORGAN #75033,
Defendants. _____________________________________________________________________________ MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANTS ______________________________________________________________________________ The Defendants, by and through their counsel and in accordance with Local Rule D.C. Colo. LCivR 83.3, hereby move the Court for an order allowing one of their current attorneys, Helen Raabe, to withdraw as counsel of record and allowing their other current attorneys, Stan

Case 1:03-cv-00140-MSK-CBS

Document 123

Filed 07/22/2005

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M. Sharoff, Assistant City Attorney of the City and County of Denver and David J. Bruno, Esq. to continue their representation of the Defendants. IN SUPPORT OF THIS MOTION, the Defendants state as follows: 1. Helen Raabe was formerly the acting City Attorney of the City and County of

Denver and in this capacity her name was routinely included as an attorney in all suits involving the City and County of Denver or any of its employees. 2. Ms. Raabe has not played an active role in the instant action, nor has she appeared

at any of the proceedings or formally entered her appearance in any other manner. 3. 4. 5. Defendants. WHEREFORE, the Defendants request that the Court enter an order granting Ms. Raabe's motion to withdraw. Respectfully submitted, HELEN RAABE Assistant City Attorney s/Helen Raabe____________________ Helen Raabe Denver City Attorney's Office Airport Legal Services 8500 Peña Boulevard Denver, CO 80249 Telephone: 303-342-2565 Fax No: 303-342-2552 E-mail:[email protected] Messrs. Sharoff and Bruno will continue to represent the Defendants. Ms. Raabe's withdrawal will not delay this litigation or prejudice any parties. Pursuant to Colo. LCivR 83.3, notice of this motion has been provided to the

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Case 1:03-cv-00140-MSK-CBS

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STAN M. SHAROFF Assistant City Attorney

s/Stan M. Sharoff_____________________ Assistant City Attorney Denver City Attorney's Office Litigation Section 201 West Colfax Avenue, Dept. 1108 Denver, CO 80202-5332 Telephone: (720) 913-3100 FAX: 720-913-3190 E-mail: [email protected] CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on the 22nd day of July, 2005, I electronically filed the foregoing MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANTS with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email address: [email protected] I hereby certify that I have mailed the MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANTS to the following non CM/ECF participants: Zebedee E. Hall F.C.I., P.O. Box 6000 Florence, Colorado 81226

Sgt. Berdahl #86059, Tech. Canino #91041, Tech. Grothe #95015, Tech. Gilworth #89044, Tech. Delmenico #89029, Tech. Fox #87026, Tech. Broden #90026, Tech. Moen #91027, Tech. Laurtia #83011, Tech. Mckihhen #86042, Tech. Titus #93013,
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Case 1:03-cv-00140-MSK-CBS

Document 123

Filed 07/22/2005

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Tech. Meyer #89041, Tech. Brennan #95035, Ofc. Nebel #97015, and Sgt. Organ #75033,

Denver Police Department Civil Liabilities Bureau 1331 Cherokee Street Denver, CO 80202

s/Marilyn Montoya_________________ Marilyn Montoya Legal Secretary Denver City Attorney's Office

G:\Litigation\WRIGHML\Fax Cover Sheets\Helen Raabe' Motion to Withdraw.doc s

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