HomeMy WebLinkAbout2019-cv-901 - Surat v. City of Fort Collins, et al. - 114 - MOTION TO WITHDRAW - GILLIAN DALE FOR DEFENDANTSIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 19-cv-00901-WJM-NRN
MICHAELLA LYNN SURAT,
Plaintiff,
v.
RANDALL KLAMSER in his individual capacity, and
CITY OF FORT COLLINS, a municipality,
Defendants.
MOTION TO WITHDRAW
Gillian Dale, counsel for Defendants Randall Klamser and City of Fort Collins
(“Defendants”), in the above-captioned matter, hereby moves the Court for an Order allowing her
to withdraw as counsel of record:
1. Certificate Pursuant to D.C.COLO.LCivR.7.1: Because of this motion is brought
pursuant to D.C.COLO.LAtty5(b), conferral is not required. See D.C.COLO.L.CivR7(b)(4).
2. Ms. Dale will no longer be employed by Hall & Evans, L.L.C. effective October
8, 2020.
3. Mark S. Ratner, Esq., and Brenden Desmond, Esq., of Hall & Evans, L.L.C., and
John R. Duval, Esq., Deputy City Attorney will continue to represent Defendants.
4. Defendants have received notification of the proposed withdrawal.
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5. Because of the continuous representation, Ms. Dale did not notify Defendants that
they are responsible for complying with all court orders and time limitations, nor that they are
required to obtain legal counsel, as would otherwise be required by D.C.Colo.LAttyR5(b).
WHEREFORE, undersigned counsel respectfully requests that the Court grant this Motion
and permit her to withdraw as counsel for the Defendants Randall Klamser and City of Fort
Collins.
Respectfully submitted this 6th day of October, 2020.
s/Gillian Dale
Mark S. Ratner, Esq.
Gillian Dale, Esq.
Brenden Desmond, Esq.
Hall & Evans, L.L.C.
1001 17th Street, Suite 300
Denver, CO 80202
303-628-3300
Fax: 303-628-3368
ratnerm@hallevans.com
daleg@hallevans.com
desmondb@hallevans.com
and
John R. Duval, Esq.
Deputy City Attorney
City of Fort Collins
P.O. Box 580
Fort Collins, CO 80522
(970) 221-6520
jduval@fcgov.com
ATTORNEYS FOR DEFENDANTS
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CERTIFICATE OF SERVICE (CM/ECF)
I HEREBY CERTIFY that on 6th day of October, 2020, 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 e-mail addresses:
David Lane
Andrew McNulty
Helen S Oh
Killmer, Lane & Newman, LLP
1543 Champa St, Suite 400
Denver, CO 80202
303-571-1000 Phone
303-571-1001 Fax
dlane@kln-law.com
amcnulty@kln-law.com
hoh@kln-law.com
Attorneys for Plaintiff
s/ Nicole Marion, Legal Assistant to
Hall & Evans, L.L.C.
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