HomeMy WebLinkAbout2018CV149 - SUTHERLAND V. CITY OF FORT COLLINS, STEVE MILLER & IRENE JOSEY - 004A - MOTION FOR PRO HAC VICE ADMISSIONDISTRICT COURT, LARIMER COUNTY, COLORADO
201 LaPorte Avenue
Fort Collins, CO 80521
COURT USE ONLY
Plaintiff:
ERIC SUTHERLAND, pro se
v.
Defendants:
THE CITY OF FORT COLLINS, a home rule municipality
in the State of Colorado; STEVE MILLER, in his capacity as
the Larimer County Assessor and all successors in this office;
IRENE JOSEY, in her capacity as the Larimer County
Treasurer and all successors to this office; and
Indispensable Parties: THE TIMNATH DEVELOPMENT
AUTHORITY, an Urban Renewal Authority; and
COMPASS MORTGAGE CORPORATION, an Alabama
company doing business in Colorado.
Attorneys for The Timnath Development Authority and
Compass Mortgage Corporation:
Eric R. Burris, pro hac vice pending
BROWNSTEIN HYATT FARBER SCHRECK, LLP
201 Third Street NW, Suite 1800
Albuquerque, NM 87102
Telephone: 505.244.0770
Email: eburris@bhfs.com
Cole J. Woodward, #50199
BROWNSTEIN HYATT FARBER SCHRECK, LLP
410 Seventeenth Street, Suite 2200
Denver, CO 80202-4432
Phone: 303.223.1100
Email: cwoodward@bhfs.com
Case Number: 2018CV149
Division: 3C
OUT OF STATE COUNSEL’S VERIFIED MOTION REQUESTING
PRO HAC VICE ADMISSION OF ERIC R. BURRIS
Pursuant to C.R.C.P. 121 § 1-2, and Rule 221, Eric R. Burris of the New Mexico office
of Brownstein Hyatt Farber Schreck, LLP moves for pro hac vice admission to practice before
this Court in the above-captioned matter.
DATE FILED: June 5, 2018 9:38 AM
FILING ID: A3FE2FE5B7C37
CASE NUMBER: 2018CV149
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AS GROUNDS FOR THIS MOTION, Eric R. Burris states and shows the Court the
following:
1. Under Rule 221, an attorney and counselor at law in good standing from any
other jurisdiction in the United States may, in the discretion of a Colorado court of record, be
permitted to participate before the Court in a trial, argument and other proceeding in the
particular case in which the attorney is employed, provided that a member in good standing of
the Bar of the State of Colorado is associated in such cause at all stages of the case.
2. Eric R. Burris of the New Mexico office of Brownstein Hyatt Farber Schreck,
LLP is a member in good standing of the State Bar of New Mexico. Eric R. Burris is assigned
attorney registration or bar admission number 5598 in New Mexico.
3. Eric R. Burris has also not been licensed in any other jurisdictions.
4. Eric R. Burris is in good standing in all Bars wherever admitted and no
discipline or grievance proceedings have been filed or are pending.
5. Eric R. Burris has sought and been granted pro hac vice admission in the State
of Colorado in the following Larimer County District Court cases within the last five years:
2018CV30269: In the Matter of SW Prospect I25 Metropolitan District Nos. 1-7;
2018CV30270: In the Matter of Gateway at Prospect Metropolitan District Nos. 1-7;
2018CV30272: In the Matter of Rudolph Farms Metropolitan District Nos. 1-6; and
2018CV30278: In the Matter of I-25/Prospect Interchange Metropolitan District.
6. Eric R. Burris acknowledges that he is subject to all applicable provisions of the
Colorado Rules of Professional Conduct and the Colorado Rules of Civil Procedure and that he
has read such rules.
7. Cole J. Woodward, #50199, is a member in good standing of the Bar of the State
of Colorado.
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8. Cole J. Woodward will be present and participate in a meaningful and
substantial manner throughout the proceedings and trial of this matter.
9. The following are parties to the proceeding and have been notified of this
Verified Motion requesting pro hac vice admission: Plaintiff Eric Sutherland, pro se, who will
be notified via electronic mail.
10. Eric R. Burris has filed a copy of this motion with the Clerk of the Colorado
Supreme Court at the Attorney Registration Office, 1300 Broadway, Suite 510, Denver,
Colorado 80203 and paid the required fee.
11. An affidavit setting forth Eric R. Burris’ qualifications and compliance is
attached.
WHEREFORE, Out of State Counsel respectfully requests that the Court admit Eric R.
Burris pro hac vice, to practice before the Court in this case.
Respectfully submitted on the 5
th
day of June, 2018.
BROWNSTEIN HYATT FARBER SCHRECK, LLP
By: s/Eric R. Burris
Eric R. Burris, pro hac vice pending
By: s/Cole J. Woodward
Cole J. Woodward, #50199
Robert G. Rogers, #43578
Casey K. Lekahal, #46531
WHITE BEAR ANKELE TANAKA &WALDRON
Attorneys for The Timnath Development Authority and
Compass Mortgage Corporation
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CERTIFICATE OF SERVICE
I hereby certify that on this 5
th
day of June, 2018, a true and correct copy of the foregoing
OUT OF STATE COUNSEL’S VERIFIED MOTION REQUESTING PRO HAC VICE
ADMISSION OF ERIC R. BURRIS was filed with the Court and served via Colorado Courts
E-Filing System on pro se Plaintiff as follows:
By E-Mail and Regular Mail
Eric Sutherland
3520 Golden Currant Boulevard
Fort Collins, CO 80521
Phone: 970.224.4509
Email: sutherix@yahoo.com
s/Penny G. Lalonde _____________
Penny G. Lalonde, Paralegal
16870790