Free Motion to Substitute Attorney - District Court of California - California

Case 5:07-cv-03141-JF

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Filed 02/20/2008

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Robert Alan Jones, Esq. Pro hac vice RAJ LIMITED, PC 1061 East Flamingo Road, Suite #7 Las Vegas, Nevada 89119 (702) 791-0742 Telephone (702) 736-0773 Facsimile [email protected] CHRIS DIETRICH, Bar No. 092592 11300 West Olympic Boulevard Suite 800 Los Angeles, California 90064 (310) 312-6888 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE VICKI R. SEIDEL, Plaintiff v. ) ) ) ) ) ) ) )

CASE NO: 5:07-CV-03141 - JF Honorable Judge Jeremy Fogel MOTION FOR LEAVE TO WITHDRAW AS COUNSEL AND ENTER APPEARANCE FOR SUBSTITUTE COUNSEL

UNITED STATES OF AMERICA, ) Defendant. ) ____________________________________)

COMES NOW Robert Alan Jones, and Christ Dietrich, counsel of record for Plaintiff Vicki R. Seidel, and pursuant to Local Rule 11-5, prays this Court to enter its order granting leave to withdraw as counsel, and substitute new counsel as set forth below: Rob Goldstein Law Offices of Robert L. Goldstein 100 Bush Street, Suite 501 San Francisco, CA 94101 Bar No. 184226.

Case 5:07-cv-03141-JF

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Filed 02/20/2008

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1.

Counsel has represented Plaintiff in the instant case since its commencement on

June 14, 2007, and since that time has performed a substantial amount of legal work and incurred significant costs in connection with the prosecution of the case. 2. Counsel has received no remuneration from Plaintiff for the legal work performed

and costs incurred by Counsel. 3. Plaintiff is unable to pay for any of her substantial legal bills, and Counsel is no

longer able to bear the financial burden that has resulted from Plaintiff's inability to pay.

WHEREFORE, the Plaintiff prays that the Court grant the instant motion granting the

undersigned Leave to Withdraw as Counsel of Record, and to substitute new counsel.

DATED: This 14th day of February, 2008.

Respectfully submitted,

/s/ Robert Alan Jones Robert Alan Jones, Esq. Pro hac vice RAJ LIMITED, PC 1061 East Flamingo Road, Suite #7 Las Vegas, Nevada 89119 (702) 791-0742 Telephone (702) 736-0773 Facsimile [email protected]

Case 5:07-cv-03141-JF

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Filed 02/20/2008

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/s/ Chris Dietrich CHRIS DIETRICH, Bar No. 092592 11300 West Olympic Boulevard Suite 800 Los Angeles, California 90064 (310) 312-6888

Case 5:07-cv-03141-JF

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CERTIFICATE OF SERVICE I hereby certify that I have this 14th day of February, 2008, served a copy of the above and foregoing MOTION TO WITHDRAW AS COUNSEL OF RECORD on the Plaintiff and all other parties who have appeared in the case by U.S. Mail, Postage Prepaid, properly addressed as follows: Vicki R. Seidel 25360 Boots Rd Monterey, CA 93940 Chris Dietrich 11300 West Olympic Boulevard, Suite 800 Los Angeles, CA 90064 David L. Denier United States Attorney's Office 450 Golden Gate Ave., Box 36055 San Francisco, CA 94102

Robert Alan Jones