Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:02-cv-02220-PSF-PAC

Document 124

Filed 09/30/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No. 02-cv-2220-PSF-PAC

RAY LEVELLE, Plaintiff, v. PENSKE LOGISTICS, Defendants. _____________________________________________________________________________ PLAINTIFF'S MOTION TO BORROW RECORD (TRANSCRIPT)
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Plaintiff, Ray LeVelle, by and through his undersigned attorneys, respectfully requests that the Court grant him permission to borrow the transcripts prepared in this matter, and as grounds therefore, states as follows: 1. An appeal was filed in this matter on May 3, 2005, by Defendant, Penske

Logistics. Plaintiff filed a cross appeal on May 12, 2005. 2. The transcript of the proceedings in this matter was completed. See Document

Nos. 117, 118, 119, 120, 121 and 122. Mr. LeVelle needs the transcript in order to prepare his briefs in this matter. 3. The transcript is approximately 800 pages long. Because of the length of the

transcript, Mr. LeVelle would like to borrow the transcript documents and have them copied at a local copy center. He would retain them for no longer than 2 days. WHEREFORE, Plaintiff, Ray LeVelle, by and through his undersigned attorneys, respectfully requests that the Court grant him permission to borrow the transcripts prepared in this matter.

Case 1:02-cv-02220-PSF-PAC

Document 124

Filed 09/30/2005

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Dated this 30th day of September, 2005.

Respectfully Submitted,

s/Patricia S. Bangert __________________________________ Patricia S. Bangert, Esq. Special Counsel to Lohf, Shaiman, Jacobs, Hyman & Feiger, P.C. 950 S. Cherry Creek Street Suite 900 Denver, CO 80246 Phone: (303) 753-9000 Fax: (303) 753-9997 E-mail: [email protected] Attorney for Plaintiff

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Case 1:02-cv-02220-PSF-PAC

Document 124

Filed 09/30/2005

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CERTIFICATE OF SERVICE I hereby certify that on September 30, 2005, I electronically filed the foregoing using the CM/ECF system, which will send notification of such filing to the following:

Frank A. Nachman J. Daniel Rodriguez Littler Mendelson 1200 17th Street, Suite 2850 Denver, CO 80202-5835 (303) 629-6200 Attorneys for Defendant

s/Patricia S. Bangert ______________________________

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