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Home My WebLink About2021CV30426 - City Of Fort Collins V. Aaron Million, Jordan Fox-Million; Million Agricultural Investments, Ltd., Arlo Richardson Aka Arlo Lee Richardson; The Pleasant Valley And Lake Canal Ditch Company - 026 - Motion Withdraw 1 of 5 District Court, Larimer County, Colorado 201 LaPorte Avenue, Suite 100 Fort Collins, Colorado 80521 (970) 494-3500 ▲ COURT USE ONLY ▲ Plaintiff: CITY OF FORT COLLINS, a Colorado home rule municipality, v. Defendants: AARON MILLION aka AARON P. MILLION; JORDAN FOX-MILLION; MILLION AGRICULTURAL INVESTMENTS, LTD., a Colorado limited partnership; ARLO RICHARDSON aka ARLO LEE RICHARDSON; THE PLEASANT VALLEY AND LAKE CANAL DITCH COMPANY; and ALL UNKNOWN PERSONS WHO CLAIM AN INTEREST IN THE SUBJECT MATTER OF THIS ACTION. Attorneys for Defendants Aaron Million aka Aaron P. Million, Jordan Fox-Million, Million Agricultural Investments, Ltd., a Colorado limited partnership, and Arlo Richardson aka Arlo Lee Richardson Crystal J. McDonough, #44621 Scott Slawson, #46001 McDonough Law LLC 1635 Foxtrail Drive Loveland, CO 80538 Phone: 970-776-3311 Fax: 877-800-5583 crystal@mcdonoughlawllc.com scott@mcdonoughlawllc.com Case No.: 2021CV030426 Courtroom: 5B UNOPPOSED MOTION TO WITHDRAW AS ATTORNEY OF RECORD; REQUEST TO RESCHEDULE CASE MANAGEMENT CONFERENCE HEARING Counsel for defendants, Aaron Million aka Aaron P. Million, Jordan Fox-Million, and Million Agricultural Investments, Ltd., a Colorado limited partnership, (collectively the “Million Defendants”), hereby moves to withdraw as attorney of record for these parties. Additionally, undersigned counsel requests that the Case Management Conference scheduled for January 3, 2022 be continued to a date after the hearing on this motion. DATE FILED: December 22, 2021 3:48 PM FILING ID: 6921E6D2B7C51 CASE NUMBER: 2021CV30426 2 of 5 1. C.R.C.P. 121, §1-15(8) Certificate of Conferral. Undersigned counsel has conferred with counsel for Plaintiff regarding this motion. The motion is unopposed. 2. On December 20, 2021, defendants Aaron Million and Million Agricultural Investments, LTD., a Colorado limited partnership terminated the representation of this firm. 3. On December 22, 2021, defendant Jordan Million terminated the representation of this firm. 4. This firm also represents defendant Arlo Richardson in this action. Defendant Richardson has sold the property at issue in this litigation and therefore has no interest in the property. A disclaimer of interest will soon be filed on his behalf. 5. Pursuant to C.R.C.P. 121 Section 1-1(b), an attorney may withdraw from a case at the discretion of the court after a motion to withdraw has been filed and served on the client and the other parties of record or their attorneys and either the consent of both the client and all counsel for the other parties is presented in writing at or after the time of the service of said motion, or at least 14 days have expired after service of the motion. 6. With this filing, pursuant to C.R.C.P. 121 Section 1-1(b)(I) – (VI) the Million Defendants are advised that: a. They shall keep the court and the other parties informed where notices, pleadings or other papers may be served; b. If they fail or refuse to comply with all court rules and orders, they may suffer possible dismissal, default or other sanctions; c. The dates of any proceedings, including trial, which dates will not be delayed nor proceedings affected by the withdrawal of counsel. These dates, as listed in the Case Procedure Order pursuant to C.R.C.P. 16 (attached as Exhibit A) are: i. 12/27/2021 – File Proposed Case Management Order ii. 1/3/202 – Case Management Conference d. The Million Defendants and the other parties have the right to object to the motion to withdraw within 14 days after service of this motion; and e. If the client is not a natural person, that it must be represented by counsel in any court proceedings unless it is a closely held entity and first complies with section 13-1-127, C.R.S. 7. The client's last known address and telephone numbers are: Aaron Million aka Aaron P. Million and Jordan Fox-Million: 1436 West Oak Fort Collins, CO 80521 970-490-1306 3 of 5 Million Agricultural Investments, LTD., a Colorado limited partnership 245 S Cascade Ave. Montrose, CO 8140 (mailing address) PO Box 25 Montrose, CO 81401 970-490-1306 8. Because the statutory time for hearing of this motion overlaps with the January 3, 2022 Case Management Conference, counsel herein requests that the hearing be continued until after this motion is decided. Counsel for Plaintiff does not object to this request. WHEREFORE, the attorney of record respectfully requests that the Court enter an order granting the motion to withdraw as attorney of record. Respectfully submitted this 22nd day of December 2021. Respectfully submitted, MCDONOUGH LAW LLC Original signature on file at the offices of McDonough Law LLC pursuant to C.R.C.P. 121 Sec. 1-26 /s/ Scott Slawson Scott Slawson, #46001 1635 Foxtrail Drive Loveland, CO 80538 P: (970) 776-3311 F: (877) 800-5583 scott@mcdonoughlawllc.com Attorney for Defendants Aaron Million aka Aaron P. Million, Jordan Fox-Million, Million Agricultural Investments, Ltd., a Colorado limited partnership, and Arlo Richardson aka Arlo Lee Richardson 4 of 5 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 22nd day of December 2021, a true and correct copy of the foregoing MOTION TO WITHDRAW AS ATTORNEY OF RECORD was filed and served via the Colorado Courts E-filing System upon the following parties of record: Peter J. Dauster Daniel M. St. John II Johnson Muffly & Dauster, PC 323 South College Avenue, Suite 1 Fort Collins, CO 80524 pdauster@nocolawgroup.com dstjohn@nocolawgroup.com Aaron Million aka Aaron P. Million 1436 West Oak Fort Collins, CO 80521 million_1@hotmail.com Jordan Fox-Million 1436 West Oak Fort Collins, CO 80521 million_1@hotmail.com Million Agricultural Investments, LTD., a Colorado limited partnership 245 S Cascade Ave. Montrose, CO 8140 (mailing address) PO Box 25 Montrose, CO 81401 million_1@hotmail.com The Pleasant Valley and Lake Canal Ditch Company 160 W. Mountain Avenue Fort Collins, CO 80524 Courtesy Copy To: Charles Bewley Counsel for Arlo Richardson aka Arlo Lee Richardson 370 17th St. Denver, CO 80202 cabewley@gmail.com 5 of 5 Courtesy Copy To: Ingrid E. Decker Fort Collins City Attorney’s Office 300 W. LaPorte Avenue Fort Collins, CO 80521 caoadmin@fcgov.com s/ Loni M. Gaudet Paralegal, McDonough Law LLC loni@mcdonoughlawllc.com