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

Case 1:04-cr-00153-LTB

Document 481

Filed 09/01/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Action No. 04 - cr - 00153 LTB UNITED STATES OF AMERICA, Plaintiff, v. 1. GERALD P. SMALL, III Defendant.

MOTION TO WITHDRAW AS ATTORNEY OF RECORD

COMES NOW Robert J Driscoll of Driscoll Law Office, attorney of record for . Amerifunding/Amerimax Realty Group, Inc. (Hereinafter "Amerifunding") in the above captioned case and move this Honorable Court for an Order for an Order granting him leave to withdraw as counsel of record for Amerifunding. In furtherance and support of this action counsel would show unto the Court the following: 1. Undersigned counsel wishes to withdraw from the above captioned case

due to the fact that undersigned counsel has not been paid for his work and the officers of Amerifunding will not communicate with him or respond to his effort to do so. 2. Court. 3. The last known mailing address for Amerifunding is 455 Sherman St, Suite This matter does not currently have any proceedings scheduled before the

#310, Denver, Colorado 80203.

Case 1:04-cr-00153-LTB

Document 481

Filed 09/01/2006

Page 2 of 2

4.

A true and correct copy of this Motion to Withdraw as Counsel of Record

has been mailed this date to Amerifunding's last known address. 5. The client, Amerifunding, is hereby advised that it has a right to object to the

withdrawal of counsel in writing within 20 days of service of this Motion to Withdraw as Counsel of Record. 6. Amerifunding is hereby advised of its duty to inform the Court of its current

mailing address at all times. 7. 8. Notice to Client is attached as Exhibit "A". Notification of Service is attached as Exhibit "B".

WHEREFORE Robert J ustin Driscoll of Driscoll Law Office moves this Honorable Court for an Order granting him leave to withdraw as counsel for Amerifunding/Amerimax Realty Group, Inc. Respectfully submitted this 1ST day of September, 2006. D RISCO LL LAW O FFICE Duly signed original on file at Driscoll Law Office /s Robert J ustin Driscoll Robert J Driscoll, Atty Reg. No. 5729 . 455 Sherman Street, Suite 310 Denver, CO 80203 (303) 534 - 3233

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