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

Case 1 :04-cv-01238-JJF Document 25 Filed 06/20/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LEARY ENTERPRISES, INC., )
a Delaware corporation, )
Plaintiff, g
v. i C.A. N0. 04-1238-JJF
THE TRAVELERS INDEMNITY i
COMPANY, )
Defendant. g
MOTION TO WITHDRAW AS ATTORNEYS FOR PLAINTIF F
Pursuant to Local Rule 83.7, Robert J. Katzenstein and Smith, Katzenstein & Furlow,
LLP (together, "SKF"), attorneys for plaintiff respectfully move that the Court permit SKF
to withdraw their appearance as attorneys in this case for plaintiff Leary Enterprises, Inc. In
support thereof SKF states the following:
1. SKF believes that good cause exists to terminate their representation of
plaintiff under Rule 1.16 ofthe Delaware Rules of Professional Conduct. The undersigned,
Robert J. Katzenstein, hereby certifies that withdrawal can be accomplished without material
adverse effect on the interests of the plaintiff
2. While this motion is being served on Travis Leary and Paul J. Leary, Sr.,
pursuant to Local Rule 83 .7, the undersigned hereby certifies that he previously sent written
notice that this motion would be filed and that each of the two Messrs. Leary provided
written acknowledgment of the receipt of such notice.
04091|Mon1002v29s.wi>n

Case 1:04-cv-01238-JJF Document 25 Filed 06/20/2007 Page 2 of 2
SMITH, KATZENSTEIN & FURLOW LLP
Robert J. lzatzenstéin (Delaware Bar ID No. 378)
800 Delaware Avenue, 10‘h Floor
P.O. Box 410
Wilmington, DE 19899 (Courier 19801)
Telephone: 302.652.8400
Telecopyz 302.652.8405
Attorneys for Leary Enterprises, Inc., plaintiff
Dated: June 20, 2007
04091|MOTll0027295.WPD 2