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

Case 1:02-cv-01662-RPM

Document 295

Filed 05/08/2006

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THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-CV-1662 (RPM) ROBERT HUNTSMAN and CLEAN FLICKS OF COLORADO, L.L.C., Plaintiffs, and CLEAN CUT CINEMAS, CLEANFLICKS, et al., Counterclaim Defendants v. STEVEN SODERBERGH, ROBERT ALTMAN, et al., Defendants and Counterclaimants and THE DIRECTORS GUILD OF AMERICA, Defendant-in-Intervention and Counterclaimant-in-Intervention, and METRO-GOLDWYN-MAYER STUDIOS, INC., TIME WARNER ENTERTAINMENT COMPANY, L.P., SONY PICTURES ENTERTAINMENT, DISNEY ENTERPRISES, INC., DREAMWORKS L.L.C., UNIVERSAL CITY STUDIOS, INC., TWENTIETH CENTURY FOX FILM CORPORATION, and PARAMOUNT PICTURES CORPORATION, Co-Defendants and Counterclaimants. ____________________________________________________________________ MOTION FOR WITHDRAWAL OF COUNSEL ____________________________________________________________________

Case 1:02-cv-01662-RPM

Document 295

Filed 05/08/2006

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Pursuant to D.C.Colo.LCivR 83.3(D), Scott J. Mikulecky of the law offices of Sherman & Howard L.L.C., respectfully moves for an Order of this Court permitting him to withdraw as counsel in this action for Play it Clean Video, LLC ("Play it Clean"). As grounds for this Motion, Movant states: 1. 2. Movant originally entered his appearance in this matter on March 5, 2003. Sherman & Howard L.L.C., has incurred legal fees and costs in representing Play

it Clean in this action. Play it Clean has stated it is unable to pay any legal fees and litigationrelated expenses. 3. Play it Clean is not facing any pending deadlines in this action; however, Scott J.

Mikulecky will attend the May 10th hearing in this case. 4. NOTICE IS HEREBY GIVEN to manager of Play it Clean, Joanne Moulton, of

the withdrawal of the Movant and Play it Clean will be responsible for complying with all court orders and time limitations established by any applicable rules. 5. NOTICE IS FURTHER GIVEN that Play it Clean, as a legal entity, cannot appear

without counsel admitted to practice before this Court, and absent prompt appearance of substitute counsel, pleadings, motions, and other papers may be stricken and default judgment or other sanctions may be imposed against Play it Clean. WHEREFORE, for good cause shown herein, Movant Scott J. Mikulecky of Sherman & Howard L.L.C., respectfully request that this Court issue an Order allowing the Movant to withdraw from this matter as counsel for Play it Clean.

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Case 1:02-cv-01662-RPM

Document 295

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DATED this 8th day of May, 2006. SHERMAN & HOWARD L.L.C.
Signed Original on File at Sherman & Howard LLC /s/ Scott J. Mikulecky

By: Scott J. Mikulecky, Esq. 90 South Cascade Avenue, Suite 1500 Colorado Springs, CO 80903 Phone: (719) 475-2440 Fax: (719) 635-4576 Attorneys for Plaintiffs

CERTIFICATE OF MAILING I hereby certify that on May 8, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: [email protected]; [email protected] Mark A. Wielga, Esq. Nathan M. Longenecker, Esq. Tempkin Wielga and Hardt LLP 1900 Wazee Street, Suite 303 Denver, CO 80202 [email protected] Ernest Getto, Esq. Latham and Watkins 633 West 5th Street, Suite 4000 Los Angeles, CA 90071 [email protected] Jonathan Zavin, Esq. Loeb & Loeb, LLP 345 Park Avenue New York, NY 10154

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Case 1:02-cv-01662-RPM

Document 295

Filed 05/08/2006

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[email protected]; [email protected]; [email protected] Christopher P. Beall, Esq. Natalie Marie Hanlon-Leh, Esq. Thomas Buchan Kelley, Esq. Faegre & Benson, LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, CO 80203 [email protected]; [email protected] Cameron T. Chandler, Esq. Kathleen Craigmile, Esq. Bennington, Johnson, Biermann & Craigmile, LLC 370 17th Street, Suite 3500 Denver, CO 80202 [email protected] Ericka Zimmer Enger Dorsey & Whitney, LLP-Colorado 370 17th Street, #4700 Denver, CO 80202-5647 And by U.S. First Class Mail to: Joann Moulton Play It Clean Video 1036 Skyline Drive Saint George, UT 84770

Signed Original on File at Sherman & Howard L.L.C. /s/ Kismet E. Skolnicki

Kismet E. Skolnicki

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