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

1 ase 3:03-cv—OO636-JBA Document 99 Filed 10/02/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
EVELINE GOINS :
H Plaintiff :
_ : CIVIL ACTION NO.
p v. : 3:03CV 636 (JBA)
I JBC & ASSOCIATES, P.C.,
JACK H. BOYAJIAN, :
MARVIN BRANDON : OCTOBER 2, 2006
Defendants. : ·
MOTION TO WITHDRAW AS COUNSEL
Pursuant to L.Civ.R. Rule 15, the undersigned attorney hereby moves for permission to
withdraw as attorney for the defendants, JBC & ASSOCIATES, P.C., JACK H. BOYAJ IAN and
J MARVIN BRANDON, in the above entitled matter. Attached to this motion is the notice to
such parties as required. Said notice has been sent by certified mail, return receipt requested, to
the defendants at their last known address, 2 Broad Street, 6th Floor, Bloomfield, NJ 07003,
giving the defendants notice of this motion. As grounds for this motion, the undersigned states
that there has been inadequate communication between attorney and clients for there to be
1 effective representation. This case went to judgment several months ago and this office has
received no communications from the clients since that time, despite several letters and
telephone messages left at the clients’ office seeking direction as to a number of post-judgment
matters. Counsel for the Plaintiff does not obj ect to this motion to withdraw.
MACDERMID, REYNOLDS 8e GLISSMAN, P.C.
ATTORNEYS AT LAW {
86 FARM1NcToN AVENUE • HARTFoRD, CONNECTICUT 06105 • TEL. (860) 278-1900 • FAX (860) 547-1191 • JuR1s No. 408391

4 ase 3:03-cv—OO636-JBA Document 99 Filed 10/O2/2006 Page 2 of 3
p DEFENDANTS,
M-» 9*‘“9" Zi
A 5 I »e‘{e fw A
By: gf
Edward S. S elton
Federal Bar Number (ctl 97 22)
MacDermid, Reynolds & Glissman, P.C.
86 Farmington Avenue
( Hartford, CT 06105
_ Tel. (860) 278-1900
Fax (860) 547-1191
[email protected]
CERTIFICATION
This is to certify that a copy of the foregoing motion to withdraw as counsel was
forwarded via first class mail, postage prepaid this 2nd day of October, 2006 to the following
counsel of record: ·
Joanne S. Faulkner, Esq.
123 Avon Street —
New Haven, CT 06511-2422
. Edward sQ elton
MAcDERM11:>, REYNOLDS & GLISSMAN, P.C.
ATTORNEYS AT LAW
B6 FARMINGTON AVENUE • HARTFORD, CONNECTICUT O6105 • TEL. (860) 278-1900 • FAX (860) 5474191 • JURIS NO. 408391

· Case 3:03-cv—OO636-JBA Document 99 Filed 10/O2/2006 Page 3 of 3
i UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
EVELINE GOINS :
Plaintiff, :
,_ : CIVIL ACTION NO.
v. : 3:03CV 636 (JBA)
, IBC & ASSOCIATES, P.C.,
JACK H. BOYAJIAN, :
MARVIN BRANDON : OCTOBER 2, 2006 I
Defendants. :
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
TO: JACK H. BOYAIIAN
MARVIN BRANDON
IBC & ASSOCIATES, P.C.
·· 2 Broad Street, 6th Floor
Bloomfield, NJ 07003
NOTICE
l. This office is filing a motion seeking the court’s permission to withdraw from
representing IBC & Associates, P.C., I ack H. Boyajian and Marvin Brandon, in the matter of
Eveline Goins v. IBC & Associates, P.C., et al., Civil Action No.: 3:03-CV-636 (JBA) in the
United States District Court, District of Connecticut at New Haven;
2. If you wish to be heard with respect to the motion, you should contact the clerl<’s office
_ to find out the date and time of the hearing;
_ 3. You may appear in court on the date and time of the hearing at the United States District
Court, District of Connecticut at New Haven, 141 Church Street, New Haven, CT 06510 and
address the court;
4. If the motion to withdraw is granted, you should either obtain another attomey or file an
I appearance on your own behalf with the court; and
5. If you do not obtain another attomey or file an appearance on your own behalf you will
not receive notices of court proceedings in the case and a default judgment may be rendered
against you.
K By: Q 2
, Edward . helton
Its Attorneys
Federal Bar #ctl9722