Free Motion to Continue - District Court of Colorado - Colorado

Case 1:02-cv-01950-EWN-OES

Document 907

Filed 09/21/2006

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF COLORADO Civil Action No. 02-cv-01950-EWN-OES KAY SIEVERDING, et al. Plaintiffs, v. COLORADO BAR ASSOCIATION, et al. Defendants. _____________________________________________________________________________ PLAINTIFF KAY SIEVERDING'S MOTION TO CONTINUE SHOW CAUSE HEARING _____________________________________________________________________________ 1. On August 15, 2006, this Court entered an Order that Plaintiff Kay Sieverding show cause why she should not be held in contempt of court for violation of various court orders directing that she not file pro se pleadings. That order set a hearing date of September 22, 2006. 2. On September 21, 2006, this Court appointed the Office of the Federal Public Defender to represent Plaintiff in connection with the civil contempt and any related criminal contempt issues, citing the risk that Plaintiff faced of incarceration in support of that appointment of counsel. 3. On September 21, 2006, counsel entered his appearance on the case. That same day, he began the process of reviewing the extensive file in the case, including inter alia, the more than nine hundred docket entries and their associated pleadings and orders. He also contacted Plaintiff to inform her of his entry into the case and to ascertain how she wished to proceed. 4. The pleadings in this case, and other cases preceding and following it which were filed by Plaintiff or in which she is otherwise involved, are extensive.

Case 1:02-cv-01950-EWN-OES

Document 907

Filed 09/21/2006

Page 2 of 4

5. Counsel currently represents almost thirty other persons on a variety of federal criminal matters. Counsel regularly practices criminal defense, not civil litigation, despite a brief stint almost twenty years ago at a large New York civil litigation firm. He certainly does not deal ever with civil contempt issues or the myriad legal issues posed by this case. 6. It will require a significant amount of time for counsel to review, research, investigate, and assimilate all that he must in order to provide the Plaintiff with effective assistance of counsel in this case. So, counsel will be asking for a substantial continuance of this hearing. WHEREFORE Plaintiff respectfully requests that this Court continue the Show Cause hearing from September 22, 2006 to a later date convenient to the Court and all parties. Respectfully submitted, RAYMOND P. MOORE Federal Public Defender

s/ Edward R. Harris Edward R. Harris Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant

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Case 1:02-cv-01950-EWN-OES

Document 907

Filed 09/21/2006

Page 3 of 4

CERTIFICATE OF SERVICE

I hereby certify that on September 21, 2006, I electronically filed the foregoing MOTION TO CONTINUE SHOW CAUSE HEARING with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Christopher P. Beall [email protected],[email protected] David R. Brougham [email protected],[email protected],[email protected] Brett Norman Huff [email protected],[email protected] Thomas Buchan Kelley [email protected],[email protected] Randall W. Klauzer [email protected] Patricia Jean Larson [email protected] Michael T. McConnell [email protected],[email protected],[email protected] Michael J. O'Malley [email protected] Ronald August Podboy [email protected] Meghan Elizabeth Pound [email protected],[email protected] J. Richard Tremaine [email protected],[email protected] Traci L. Van Pelt [email protected],[email protected],[email protected]

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Case 1:02-cv-01950-EWN-OES

Document 907

Filed 09/21/2006

Page 4 of 4

and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participant in the manner (mail, hand-delivery, etc.) indicated by the non-participant's name: Kay Sieverding 641 Basswood Avenue Verona, WI 53593

s/ Edward R. Harris Edward R. Harris Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant

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