HomeMy WebLinkAbout2018CV149 - SUTHERLAND V. CITY OF FORT COLLINS, STEVE MILLER & IRENE JOSEY - 139 - OUTOF STATE COUNSEL'S SECOND VERIFIED MOTION REQUESTING CONTINUED PRO HAC VICE ADMISSION OF ERIC R. BURRISDISTRICT COURT, LARIMER COUNTY, COLORADO
201 LaPorte Avenue
Fort Collins, CO 80521
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.
• COURTUSEONLY •
Attorneys for The Timnath Development Authority and
Compass Mortgage Corporation:
Eric R. Burris, pro hac vice admitted
BROWNSTEIN HYATT FARBER SCHRECK, LLP
201 Third Street NW, Suite 1800
Albuquerque, NM 87102
Telephone: 505.244.0770
Email: eburris@bhfs.com
Chloe Mickel, #50437
Jesse D. Sutz, #52395
BROWNSTEIN HYATT FARBER SCHRECK, LLP
41 O Seventeenth Street, Suite 2200
Denver, CO 80202-4432
Phone: 303.223.1100
Email: cmickel@bhfs.com; jsutz@bhfs.com
Case Number: 2018CV149
Division: 3C
OUT OF STATE COUNSEL'S SECOND VERIFIED MOTION REQUESTING
CONTINUED PRO HAC VICE ADMISSION OF ERIC R. BURRIS
DATE FILED: May 28, 2019 2:30 PM
FILING ID: 7E67E947278D0
CASE NUMBER: 2018CV149
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 the continuation of pro hac vice admission
to practice before this Court in the above-captioned matter.
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. Fric 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 sought and was granted pro hac vice admission in this matter on
June 27, 2018 under the sponsorship of Cole J. Woodward, who has now left the law firm of
Brownstein Hyatt Farber Schreck, LLP. Out of an abundance of caution, Eric R. Burris now
seeks admission under the sponsorship of Jesse D. Sutz.
6. Eric R. Burris has also 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:
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2018CV30269: In the Matter of SW Prospect 125 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;
2018CV30278: In the Matter ofl-25/Prospect Interchange Metropolitan District;
2018CV30567: The Town of Timnath, Colorado and Timnath Development Authority v.
Eric Sutherland; and
2018CV31187: Timnath Development Authority v. Eric Sutherland, Christie Mathews.
7. 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.
8. Jesse D. Sutz, #52395, is a member in good standing of the Bar of the State of
Colorado.
9. Jesse D. Sutz will be present and participate in a meaningful and substantial
manner throughout the proceedings and trial of this matter.
10. The following are parties to the proceeding and have been notified of this
Verified Motion requesting continued pro hac vice admission:
Plaintiff Eric Sutherland, pro se Notified via E-mail
Defendant City of Fort Collins Counsel Notified via Colorado Courts
E-Filing System
Defendants Steve Miller, Assessor Counsel Notified via Colorado Courts
Irene Josey, Treasurer E-Filing System
11. Jesse D. Sutz has filed a copy of this motion with the Clerk of the Colorado
Supreme Court at the Attorney Registration Office, 1300 Broadway, Suite 51 O, Denver,
Colorado 80203. As Mr. Burris was admitted in this matter previously, an additional fee is not
required.
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12. An affidavit setting forth Eric R. Burris' qualifications and compliance is
attached.
WHEREFORE, Out of State Counsel respectfully requests that the Court continue Eric
R. Burris' pro hac vice admission to practice before the Court in this case.
Respectfully submitted on the zs" day of May, 2019.
STATE OF NEW MEXICO
COUNTY OF BERNALILLO
The foregoing instrument was subscribed and s,vorn before me this~ day of May,
2019 by ERIC R. BURRIS.
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) SS.
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Witness my hand and official seal.
My commission expires: /0- ~- 20 20
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By: __ ){_tv __ _,...._ _
1 Chloe Mickel, 504 7
f Jesse D. Sutz, #52395
AttoUys for The Timnath Development Authority and
Compass Mortgage Corporation
STATE OF COLORADO
CITY AND COUNTY OF DENVER
)
) SS.
)
The foregoing instrument was subscribed and sworn before me this ~t'ay of May,
2019 by JESSE D. SUTZ.
Witness my hand and official seal.
My commission expires: l:>ee.lö~ .. ôOé\ I
~li~oJ
PENNY G. LALONDE
NOTARY PU8UC
STATE OF COI.ORAOo
NOTARY JD 20134059010
· MY COMIAISS,cw EXPIRES ŒCEMBER 10 2021
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CERTIFICATE OF SERVICE
I hereby certify that on this zs" day of May, 2018, a true and correct copy of the
foregoing OUT OF STATE COUNSEL'S SECOND VERIFIED MOTION REQUESTING
CONTINUED 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
sf Penny G. Lalonde
Penny G. Lalonde, Paralegal
19296248
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