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

Case 3:03-cv-01043-SRU

Document 39

Filed 09/30/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT _________________________________ : K.L.C., INC., KEYSTONE LEASING : Plaintiff : : CIVIL NO. 3:03CV1043 (SRU) vs. : : CYNTHIA TRAYNER : Defendant : ________________________________ : SEPTEMBER 29, 2004 MOTION FOR PERMISSION TO WITHDRAW APPEARANCE The undersigned attorneys Mark E. Block and Lloyd L. Langhammer move for permission to Withdraw their Appearances in the above-referenced matter. In support of said Motion, the undersigned attorneys represent as follows: 1. There has been a breakdown in communication between the attorneys and client

and as such the client's interest would be best served through representation by other counsel; and 2. The defendant Cynthia Trayner has previously appeared pro se so the withdrawal

of the appearances by the undersigned will not prejudice her or the plaintiff. COUNSEL TO THE DEFENDANT ________________________________ Mark E. Block ________________________________ Lloyd L. Langhammer for O'Brien, Shafner, Stuart, Kelly & Morris, P.C. 138 Main Street Post Office Box 310 Norwich, CT 06360 ct 01508

Case 3:03-cv-01043-SRU

Document 39

Filed 09/30/2004

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Certification I hereby certify that a copy of the foregoing was mailed, postage prepaid on September 29, 2004 to the following: Christopher G. Winans, Esquire Burrell & Winans 100 Mill Plain Road - 4th Floor P. O. Box 2809 Danbury, CT 06813-2809 and Certified Mail - Return Receipt Requested 7001 2510 0006 7655 4900 Mrs. Cynthia Trayner 13 Westside Drive, Unit #94 North Grosvenordale, CT 06255 ___________________________________ Lloyd L. Langhammer Commissioner of the Superior Court

Case 3:03-cv-01043-SRU

Document 39

Filed 09/30/2004

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NOTICE OF MOTION TO WITHDRAW TO: CYNTHIA TRAYNER This is to notify you, pursuant to Practice Book §3-10 that: (1) The law firm is filing a motion which seeks the court's permission to no longer

represent you in the above-captioned case. (2) If you wish to be heard on this motion, you should contact the clerk's office to find

out the date and time of the hearing. (3) motion. (4) If the motion to withdraw is granted, you should either obtain another attorney or You may appear in court on the hearing date and address the court concerning the

file an appearance on your own behalf with the court. (5) If you do not either obtain a new attorney or file an appearance on your own

behalf with the court, you will not receive notice of court proceedings in the case and a nonsuit or default judgment may be rendered against you. Respectfully submitted, ______________________________ Mark E. Block ______________________________ Lloyd L. Langhammer, for O'Brien, Shafner, Stuart, Kelly & Morris, P.C.

Case 3:03-cv-01043-SRU

Document 39

Filed 09/30/2004

Page 4 of 4

Certification I hereby certify that a copy of the foregoing was mailed, postage prepaid on September 29, 2004 to the following: Christopher G. Winans, Esquire Burrell & Winans 100 Mill Plain Road - 4th Floor P. O. Box 2809 Danbury, CT 06813-2809 and Certified Mail - Return Receipt Requested 7001 2510 0006 7655 4900 Mrs. Cynthia Trayner 13 Westside Drive, Unit #94 North Grosvenordale, CT 06255 ___________________________________ Lloyd L. Langhammer Commissioner of the Superior Court