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

t E%®V-01036-DJS Document 93 Filed O9/27/2005 Page 1 of 3
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UNITED STATES DISTRICT COURT- i
DISTRICT OF CONNECTICUT
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CALL CENTER TECHNOLOGIES, INC. - Wi Y -"-·; l ‘ ` ii F
VS. CASE NUMBER: 3:O3CV.1036
GRAND ADVENTURES TOUR & Q
I TRAVEL PUBLISHING CORPORATION, {
i INTERLINE TRAVEL & TOUR, INC. September 22, 2005
MOTION FOR WITHDRAWAL OF APPEARANCE i
i l. Pursuant to Local Rule 7(e) of the United States District Court, District of
Connecticut, Local Rules of Civil Procedure (the "Local Rules”) Attorney Jason C.
Spencer on behalf of the firm Ford Nassen & Baldwin P.C. (collectively referred to
herein as "FNB") respectfully requests permission to withdraw as pro hac vice counsel
for the Plaintiff Call Center Technologies, Inc. in the above—referenced matter. )
2. Jason C. Spencer was admitted to the Connecticut bar Pro Hac Vice under
Joel M. Shafferman, on behalf of the law firm of Solomon Pearl Heymann Blum & Stich,
LLP (collectively referred to herein as "SPI-IBS") as local counsel to assist Joel M.
Shafferman for depositions he was conducting in Austin, Texas.
3. Subsequent to the engagement of FNB in this case, Plaintiff and FNB have
· become engaged in a fee dispute which has negatively impacted the working relationship
between Plaintiff and FNB in this case. Subsequent to the engagement of SPHBS in this l
case, Plaintiff and SPHBS have become engaged in a fe dispute which has negatively
· impacted the working relationship between Plaintiff and SPHBS in this case.
4. FNB has given Plaintiff reasonable notice that it would be seeking leave to
withdraw as its counsel in this matter. g
5. If FNB were to be required to continue representing Plaintiff in this matter
it would cause FNB unreasonable financial hardship.
6. FNB has sent a copy of this motion to withdraw by e-mail, facsimile and
certified mail to Defendant.
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l ( . Case 3:03-cv—O1036-DJS Document 93 Filed O9/27/2005 Page 2 of 3
WHEREFORE, Jason C. Spencer, on behalf of the law tirm of Ford Nassen &
Baldwin P.C., respectfully requests permission to this Court to have its appearance
withdrawn as pro hac vice counsel for the Plaintiff in this matter and that FNB be granted _
such other and further relief as this court deems just and proper.
Respectfully submitted,
l FORD NASSEN & BALDWIN P.C.
I 98 San Jacinto Boulevard, Suite 1450
Austin, Texas 78701
‘ (512) 275-1781 — Direct Line
(512) 236-0009 - Main Line
(512) 236-0682 — Facsimile
By: AWE
` on C. Spe er l
` State Bar No. 00789755
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CO-COUNSEL FOR CALL CENTER
TECHNOLOGIES
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Case 3:03-cv-01036-DJS Document 93 Filed O9/27/2005 Page 3 of 3
CERTIFICATE OF SERVICE
By my signature above, I certify that a true and correct of the foregoing has been
delivered via certified mail, return recei_pt requested and/or facsimile to the following
counsel on or about the 22"'1 day of September, 2005:
Joel Shafferman
Solomon, Pearl, Blum, Heymann & Stich, L.L.P.
40 Wall Street, 35th Floor
{ New York, NW 10005
l Laura F. Baldini
i Law Office of Laura Flynn Baldini, LLC
2 Battersea Park Road, 2"d Floor \
I Farmington, CT 06032 ·
l
i Lester Sprouse
. Sprouse & Anderson
515 Congress Avenue, Suite 1212
Austin, Texas 78701 E
Courtney Baxtor I
Jackson Walker, L.L.P.
100 Congress Avenue, Suite 1100
Austin, Texas 7870]
Beatrix Bernauer
Grant Thornton ,
175 West Jackson Boulevard
Chicago, Illinois 60604
n C. Speng
66060. in 188.002
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