Free Motion to Withdraw as Attorney - District Court of Delaware - Delaware

Case 1:04-cv-00389-***-MPT

Document 85

Filed 11/20/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

PSA, Inc. Plaintiff, v. Inter-World Communications, Inc., Corpserve, S.A. de C.V., World Center of Video Conferences, S.A. De C.V., Dean Hollis Velazco, and John Remke, Defendants.

Civil Action No. 04-389-KAJ

MOTION OF CAMPBELL & LEVINE, LLC TO WITHDRAW APPEARANCE AS ATTORNEY FOR DEAN HOLLIS VELAZCO AND CORPSERVE, S.A. DE C.V. AND NOW, comes Marla Rosoff Eskin, Esquire of Campbell & Levine, LLC, and file this Motion to Withdraw Appearance under Local District Court Rule 83.7, and state as follows: 1. Dean Hollis Velazco and Corpserve, S.A. de C.V. ("Defendants") in the above-

referenced matter, engaged Marla Rosoff Eskin, Esquire ("Counsel") on or about October 2002 for purposes of representing them in their defense of the above-captioned proceeding (the "Case"). 2. As of the date hereof, Counsel has performed legal services on behalf of the

Defendants including, but not limited to, filing of an Answer, conducting case analysis, engaging in discovery, filing a dispositive motion and various Court appearances. 3. In its representation of the Defendants, Counsel worked numerous hours and

incurred extensive fees and expenses. At present, the Defendants and Counsel have a dispute regarding legal fees and expenses, both for past and future fees and expenses.
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Case 1:04-cv-00389-***-MPT

Document 85

Filed 11/20/2006

Page 2 of 2

4. 5.

Counsel has informed the Defendants of her intention to withdraw from the case. Pursuant to D. Del. Local Rule 83.7, Marla Rosoff Eskin certifies that this Motion

has been served upon the Defendant Dean Hollis Velazco by certified mail and Corpserve by registered mail at their last known address. The Defendants have also been served via electronic mail. WHEREFORE, Campbell & Levine, LLC respectfully request that this Honorable Court enter an Order withdrawing their appearance in this case. Respectfully submitted, Date: November 20, 2006 CAMPBELL & LEVINE L.L.C.

/s/Marla Rosoff Eskin Marla Rosoff Eskin (No. 2989) Kathleen Campbell Davis (No. 4229) 800 N. King Street, Suite 300 Wilmington, DE 19801 Ph. (302) 426-1900 Fax. (302) 426-9947

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