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

Case 3:03-cv-01036-DJS Document 92 Filed O9/20/2005 Page 1 of 3
UNITED STATES BANKRUPTCY COURT
DISTRICT OF CONNECTICUT
CALL CENTER TECHNOLOGIES, CIVIL ACTION NO.
: 3:03CV1036 (SRU)
Plaintiff, :
v. :
GRAND ADVENTURES TOUR &
TRAVEL PUBLISHING CORPORATION, :
INTERLINE TRAVEL & TOUR, INC. :
Defendants.
September 19, 2005
REQUEST FOR LEAVE TO WITHDRAW APPEARANCE ON BEHALF OF THE
PLAINTIFF CALL CENTER TECHNOLOGIES, INC.
1. Pursuant to Local Rule 7(e) of the United States District Court, District of
Connecticut, Local Rules of Civil Procedure (the "Local Rules") Attorney Joel M. Shafferman,
on behalf of the law firm of Solomon Pearl Heymann Blum & Stich, LLP ("SPB") respectfully
requests permission to withdraw as counsel for the Plaintiff Call Center Technologies, lnc.
("Plaintiff"), in the above referenced matter.
2. Subsequent to the engagement of SPB in this case, Plaintiff and SPB have
become engaged in a fee dispute which has negatively impacted the working relationship
between Plaintiff and the SPB in this case. This fee dispute has persisted despite repeated
written letter requests, emails and telephone calls between SPB and Plaintiff. SPB has
concluded that this dispute cannot be resolved.
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Case 3:03-cv-01036-DJS Document 92 Filed O9/20/2005 Page 2 of 3
3. SPB has given Plaintiff reasonable notice that it would be seeking leave to
withdraw as its counsel in this matter.
4. If SPB were to be required to continue representing Plaintiff in this matter it
would cause SPB unreasonable financial hardship.
5. SPB has sent a copy of this motion to withdraw by email, fax and certified mail
to Defendant and has been notified of the need to engage successor counsel in the event that
this motion is granted.
WHEREFORE, Joel M. Shafferman, on behalf of the law firm of Solomon
Pearl Heymann Bltun & Stich, LLP, respectfully requests permission of this Court to have its
appearance withdrawn as counsel for the Plaintiff in this matter and that SPB be granted such
other and further relief as this Court deems just and proper. /
R tfully submitted,
I
/oei’MT ` , Esq.
Solomon ” S lum Heymann & Stich LLP
40 Wal · eet, 35th Floor
New York, New York 10005
(212) 267-7600
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Case 3:03-cv-01036-DJS Document 92 Filed O9/20/2005 Page 3 of 3
ORDER
The foregoing Motion, having been duly presented to this Court, it is hereby
ORDERED, that the same be and hereby is GRANTED/DENIED.
THE COURT,
JUDGE/Clerk
n