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Home My WebLink About972065.tiffWELD COUNTY DISTRICT COURT, COUNTY OF WELD, STATE OF COLORADO Case No. 97 CV 340 Division I MOTION FOR EXTENSION OF TIME ELIZABETH A. WILSON, and RICHARD L. WILSON, Plaintiffs, vs. THE BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY, COLORADO, Defendants. n. v COMES NOW, the Plaintiffs, Elizabeth A. Wilson and Richard L. Wilson, by and through their attorneys, DOYLE, OTIS, FREY & HELLERICH, LLC, and hereby requests that the Court grant an extension of time in the above -captioned matter, and as grounds therefore, states as follows: 1. Plaintiffs will need additional time as counsel for the Plaintiffs has requested to with draw and Plaintiffs will need time to secure new legal counsel. Respectfully submitted this // day of August, 1997, DOYLE, OTIS, FREY & HELLERICH, LLC By: - Thomas E. Hellerich #2159 Attorney for Plaintiffs 1812 56th Avenue Greeley, CO 80634 (970) 330-6700 1 ec: ALlCf?(cruv) 972065 CERTIFICATE OF MAILING I hereby certify that on the /1 day of August, 1997, I served a true and correct copy of the foregoing by mailing a copy thereof, First Class, postage prepaid, addressed to: Bruce Barker, Esq. Lee D. Morrison, Esq. Weld County Attorneys Office 915 10th Street P. O. Box 1948 Greeley, CO 80632 Board of County Commissioners Weld County 915 10th Street Greeley, CO 80631 2 WELD COUNTY 3TY DISTRICT COURT, COUNTY OF WELD, STATE OF COLORADO Case No. 97 CV 340 Division I NO 1'lh'ICATION CERTIFICATE ELIZABETH A. WILSON and RICHARD L. WILSON, Plaintiffs, vs. CI :nsi THE BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY, COLORADO, Defendants. COMES NOW Thomas E. Hellerich and states unto the Court as follows: 1. That reasonable efforts have been made to give actual notice to the Plaintiffs of all notification requirements contained in (a) through (h) of Paragraph 2 of the Colorado Rules of Civil Procedure, Rule 121, Statewide Practice Standards Section 1-1. 2. That such notification was given to the Plaintiffs by means of a Notice of Intent to Withdraw, a copy of which is attached hereto and incorporated herein by reference. 3. That the last known names and address of the Plaintiffs are as follows: Elizabeth A. Wilson Richard L. Wilson 6707 Weld County Road 19 Fort Lupton, CO 80621 Respectfully submitted, DOYLE, OTIS, FREY & HELLERICH, LLC Byc ‘2 - Thomas E. Hellerich #2159 1812 56th Avenue Greeley, CO 80634 (970) 330-6700 CERTIFICATE OF MAILING I hereby certify that on the If day of August, 1997, I served a true and correct copy of the foregoing Notification Certificate by mailing a copy thereof, properly addressed, First Class, postage prepaid, to the following: Elizabeth A. Wilson Richard L. Wilson 6707 Weld County Road 19 Fort Lupton, CO 80621 Bruce Barker, Esq. Lee D. Morrison, Esq. Weld County Attorneys Office 915 10th Street P. O. Box 1948 Greeley, CO 80632 Board of County Commissioners Weld County 915 10th Street Greeley, CO 80631 4 -1_D c0!_,° T DISTRICT COURT, COUNTY OF WELD, STATE OF COLORADO Case No. 97 CV 340 Division I NOTICE OF INTENT TO WITHDRAW ELIZABETH A. WILSON and RICHARD L. WILSON, Plaintiffs, vs. THE BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY, COLORADO, Defendants. TO: Elizabeth A. Wilson and Richard L. Wilson, Plaintiffs YOU ARE HEREBY NOTIFIED OF THE FOLLOWING: 1. That Thomas E. Hellerich, wishes to withdraw from representing you in the above referenced case. 2. That the District Court in and for the County of Weld and State of Colorado will retain jurisdiction of the above referenced case at least until a determination of any pending matters has been made. 3. That upon the withdrawal of Thomas E. Hellerich from your representation, you will have the burden of keeping the Court informed where notices, pleadings and other papers may be served upon you. 4. That you will have the obligation to prepare for hearings or trial or hire other counsel to prepare for hearings or trial when dates have been set in the above referenced case. 5. That if you fail or refuse to meet these burdens you may suffer possible entry of Orders against you. 6. That service of process may be made upon you at your last known address. " 7. That you have a right to object within 15 days of the date of this notice to the withdrawal of Thomas E. Hellerich from your representation. DOYLE, OTIS, FREY & HELLERICH, LLC /7/ a—' X t r Thomas E. Hellerich #2159 1812 56th Avenue Greeley, CO 80634 (970) 330-6700 CERTIFICATE OF MAILING I hereby certify that on the // day of August, 1997, served a true and correct copy of the foregoing Notice of Intent to Withdraw by mailing a copy thereof, properly addressed, First Class, postage prepaid, to the following: Elizabeth A. Wilson Richard L. Wilson 6707 Weld County Road 19 Fort Lupton, CO 80621 Bruce Barker, Esq. Lee D. Morrison, Esq. Weld County Attorneys Office 915 10th Street P. O. Box 1948 Greeley, CO 80632 Board of County Commissioners Weld County 915 10th Street Greeley, CO 80631 DISTRICT COURT, COUNTY OF WELD, STATE OF COLORADO Case No. 97 CV 340 Division I" " MOTION TO WITHDRAW ELIZABETH A. WILSON and RICHARD L. WILSON, Plaintiffs, vs. THE BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY, COLORADO, Defendants. COMES NOW the law firm of Doyle, Otis, Frey & Hellerich, LLC, by Thomas E. Hellerich, and respectfully moves this Court for an order permitting Thomas E. Hellerich to withdraw his representation as counsel for the Plaintiffs, Elizabeth A. Wilson and Richard L. Wilson in the above - captioned proceedings, and as grounds therefor, states unto the Court as follows: That Thomas E. Hellerich wishes to withdraw his legal representation on behalf of the Plaintiffs in the above referenced case. 1. The undersigned counsel and the Plaintiffs are unable to agree upon how the Plaintiffs should proceed in this matter and Plaintiffs are in need of new legal counsel. 2. Plaintiffs have commenced their own legal proceedings which are a part of and parallel the within action and Plaintiffs desire to proceed forward as their own legal counsel, or should retain new legal counsel. 3. That reasonable efforts have been made to give actual notice to the Plaintiffs of the notification requirements contained in Colorado Rules of Civil Procedure, Rule 121, Statewide Practice Standards, Section 1-1 as evidenced by a Notice of Intent to Withdraw and Notification Certificate, copies of which are attached hereto and incorporated herein by reference. Respectfully submitted, DOYLE, OTIS, FREY & HELLERICH, LLC Thomas E. Hellerich #2159 Attorney for Plaintiffs 1812 56th Avenue Greeley, CO 80634 (970) 330-6700 CERTIFICATE OF MAILING I hereby certify that on the 1/ day of August, 1997, I served a true and correct copy of the foregoing Motion to Withdraw by mailing a copy thereof, properly addressed, First Class, postage prepaid, to the following: Elizabeth A. Wilson Richard L. Wilson 6707 Weld County Road 19 Fort Lupton, CO 80621 Bruce Barker, Esq. Lee D. Morrison, Esq. Weld County Attorneys Office 915 10th Street P. O. Box 1948 Greeley, CO 80632 Board of County Commissioners Weld County 915 10th Street Greeley, CO 80631 Hello