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

Case 1:02-cv-01827-RPM-GJR

Document 163

Filed 05/09/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-M-1827 (GJR) TIBERIU KLEIN, individually and as Executor of the Estate of CLAUDIA ZVUNCA, Plaintiff, vs. WESLEY JAT TATUM and GREYHOUND BUS LINES, INC., Defendants. MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF TIBERIU KLEIN NOW COME, Jeanine L. Stevens, Thomas A. Clancy and the Law Firm of Clancy & Stevens, attorneys for Plaintiff Tiberiu Klein in this matter, and respectfully request this Court grant their Motion to Withdraw, stating as follows: 1. On September 8, 2004, Jeanine L. Stevens, Thomas A. Clancy, and the Law Firm

of Clancy & Stevens filed their appearance as counsel on behalf of Plaintiff Tiberiu Klein in this matter. 2. Mr. Klein has subsequently retained James Avery as his attorney and advised the

Court on May 2, 2006 that he wishes Mr. Avery to represent him in this matter. (See Exhibit 1, Order dated May 2, 2005) 3. Tiberiu Klein. 4. As Mr. Klein indicated to the Court that he wishes Mr. Avery to represent him, On October 28, 2005, James Avery filed an appearance on behalf of Plaintiff

pursuant to D.C.Colo.L.Civ.R. 83.3(D), good cause exists to permit Jeanine L. Stevens, Thomas

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Case 1:02-cv-01827-RPM-GJR

Document 163

Filed 05/09/2006

Page 2 of 2

A. Clancy, and the Law Firm of Clancy & Stevens to withdraw as Mr. Klein's counsel in this matter. 5. Clancy & Stevens sent a Notice of Withdrawal from Representation, pursuant to

D.C.Colo.L.Civ.R. 83.3(D), to Tiberiu Klein simultaneous with this Motion. (See Exhibit 2, Notice of Withdrawal) WHEREFORE, Jeanine L. Stevens, Thomas A. Clancy, and the Law Firm of Clancy & Stevens request that this Court enter an Order granting Jeanine L. Stevens, Thomas A. Clancy, and the Law Firm of Clancy & Stevens permission to withdraw as counsel in this matter for Plaintiff Tiberiu Klein. RESPECTFULLY SUBMITTED this 9th day of May, 2006

s/Jeanine L. Stevens Jeanine L. Stevens Clancy & Stevens 29 South LaSalle Street, Suite 220 Chicago, IL 60603 312-782-2800 Attorney for Plaintiff

s/Thomas A. Clancy Thomas A. Clancy Clancy & Stevens 29 South LaSalle Street, Suite 220 Chicago, IL 60603 312-782-2800 Attorney for Plaintiff

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