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

Case 1:02-cv-01736-EWN-MJW

Document 41

Filed 08/03/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-cv-1736-EWN-MJW ROBERT STONE, Plaintiff, v. DEPARTMENT OF AVIATION, DENVER INTERNATIONAL AIRPORT and THE CITY AND COUNTY OF DENVER, Defendants. __________________________________________________________________ UNOPPOSED MOTION FOR MINDI L. WRIGHT TO INDIVIDUALLY WITHDRAW AS COUNSEL OF RECORD __________________________________________________________________ Defendants, by undersigned counsel, and Mindi L. Wright hereby move the Court for an order permitting Ms. Wright to individually withdraw as counsel of record for the Defendants, Department of Aviation, Denver International Airport and the City and County of Denver, and in support of this Motion, state the following: 1. Mindi L. Wright left the employ of the Denver City Attorney's Office on

March 31, 2006, while this matter was pending before the 10th Circuit Court of Appeals and leave was granted by that Court for her to withdraw as counsel. 2. This matter was remanded to this Court by the 10th Circuit Court of

Appeals on or about July 28, 2006, after Ms. Wright had left the City Attorney's Office.

Case 1:02-cv-01736-EWN-MJW

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3.

Assistant City Attorneys Jack M. Wesoky and Robert D. Nespor, who have

entered appearances in this case on behalf of the Defendants, will continue their representation of the Defendants in the remaining stages of this case. 3. Permitting the withdrawal of Ms. Wright will not in any way disrupt or

delay any proceedings in this case in light of the fact that Assistant City Attorneys Wesoky and Nespor will continue their representation of the Defendants in the remaining stages of this case. There would not be any break in the City Attorney's Office's representation of the Defendants. 4. Good cause exists for an order permitting Ms. Wright to individually

withdraw as counsel for the Defendant. See D.C.COLO.LCivR 83.3 D (permitting withdrawal on a motion showing good cause). 5. In compliance with D.C.COLO.LCivR 7.1 A, the Plaintiff's counsel has

been contacted concerning this Motion and advises that the Plaintiff does not oppose this motion. WHEREFORE, Mindi L. Wright respectfully requests the Court to enter an Order permitting her to individually withdraw from this matter. MINDI L. WRIGHT, ESQ. By: s/ Mindi L. Wright Mindi L. Wright, Attorney #29903 Qwest Services Corp. Legal Affairs Employment Law Group Telephone: 303-383-6584 Facsimile: 303-295-6977 E-Mail: [email protected]

Case 1:02-cv-01736-EWN-MJW

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Filed 08/03/2006

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JACK M. WESOKY Assistant City Attorney By: s/ Jack M. Wesoky Jack M. Wesoky Denver City Attorney's Office 201 W. Colfax Ave., Dept. 1108 Denver, CO 80202 Telephone: 720-913-3117 Facsimile: 720-913-3190 E-Mail: [email protected] ATTORNEY FOR DEFENDANT CERTIFICATE OF MAILING I certify that on August 3, 2006, I electronically filed the foregoing UNOPPOSED MOTION FOR MINDI L. WRIGHT TO INDIVIDUALLY WITHDRAW AS COUNSEL OF RECORD with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail address:

David Lichtenstein, Esq. E-mail: [email protected] VIA INTEROFFICE MAIL TO: James Thomas Assistant Manager of Aviation Human Resources Department of Aviation Turner West Manager Department of Aviation
s/ Yvonne Harris Yvonne Harris Office of The City Attorney