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

Case 3:00-cv-00435-JCH

Document 160

Filed 04/28/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DANTE DELORETO, ET AL. Plaintiff;

: CIVIL ACTION : : v. : NO. 3:00CV435 (JCH) : THOMAS MITNEY, HOWARD SHAW : AND KEVIN O'LEARY : Defendants. : April 28, 2006 MOTION TO WITHDRAW Pursuant to Rule 15 of the Local Rules of Civil Procedure, the undersigned attorney hereby moves this Court for permission to withdraw from any further representation of the plaintiff, Dante DeLoreto, in the above-captioned matter. In support hereof, the undersigned states as follows: 1. The undersigned does not recall filing an appearance in the above captioned case and

cannot find a copy of any such appearance. If an appearance was filed, it was to assist Jon L. Schoenhorn, whose firm the plaintiff retained. At the time of any such filing, I was an associate attorney with Jon L. Schoenhorn & Associates. 2. On January 2, 2004, I opened my own practice in Gales Ferry, Connecticut, and have

not been an associate of Jon L. Schoenhorn & Associates since. 3. My firm has not been retained to represent the plaintiff, Dante DeLoreto, and has not

represented said plaintiff in any fashion on any matter. 4. On April 27, 2006 and April 28, 2006, the plaintiff, Dante DeLoreto, has made

harassing and threatening telephone calls to the undersigned and his staff. As such, any attorneyclient relationship, which never existed in the first place, is unrealistic and the undersigned is unable to provide said plaintiff with legal representation or advice.

Case 3:00-cv-00435-JCH

Document 160

Filed 04/28/2006

Page 2 of 2

WHEREFORE, the undersigned requests that this motion be granted. BY:_______________________ T.J. Morelli-Wolfe, Esq. Federal Bar No. ct22688 Law Office of T.J. Morelli-Wolfe, PC 1663 Route 12 · PO Box 413 Gales Ferry, CT 06335

CERTIFICATION I hereby certify that a true copy of the foregoing was mailed first-class, postage prepaid, on April 28, 2006 to: Scott M. Karsten, Esq. and James N. Tallberg, Esq. Karsten & Dorman 29 South Main Street West Hartford, CT 06119 I further certify that a copy was sent by certified mail to the plaintiff, at the following address: Dante DeLoreto 33 Maxwell Drive Wethersfield, CT 06109

_____________________ T.J. Morelli-Wolfe