HomeMy WebLinkAbout2019-cv-901 - Surat v. City of Fort Collins, et al. - 069 - CHRISTINA GUNN MOTION TO WITHDRAWIN 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
Christina S. Gunn, counsel for Defendants RANDALL KLAMSER, in his individual
capacity, and CITY OF FORT COLLINS, a municipality, (collectively “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. Gunn will no longer be employed by Hall & Evans, L.L.C. effective
January 22, 2020.
3. Mark S. Ratner of Hall & Evans, L.L.C., 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. Gunn 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,
in his individual capacity, and CITY OF FORT COLLINS, a municipality.
Respectfully submitted, this 23rd day January, 2020.
s/ Mark S. Ratner, Esq.
Mark S. Ratner, Esq.
Christina S. Gunn, Esq.
Hall & Evans, L.L.C.
1001 17th
Street, Suite 300, Denver, CO 80202
ratnerm@hallevans.com
gunnc@hallevans.com
Attorneys for Defendants
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CERTIFICATE OF SERVICE (CM/ECF)
I HEREBY CERTIFY that on the 23rd day January, 2020, I electronically filed the
foregoing with the Clerk of Court using the CM/ECF system and U.S. Mail as follows:
David Lane, Esq.
Andrew McNulty, Esq.
Helen S Oh, Esq.
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
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