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

A Case 3:03-cv—O103§—DJS Document 36 Filed 05/2§/2004 Page 1 of 4
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UNITED STATES DISTRICT COURT ` QQ l> gg I
DISTRICT OF CONNECTICUT ' ? c I
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Plaintiff] ; l
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GRAND ADVENTURES TOUR & : I I
TRAVEL PUBLISHING CORPORATION, ’
INTERLINE TRAVEL & TOUR, INC., 1 I
Defendants. 1 May 27, 2004
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REQUEST FOR LEAVE TO WITHDRAW APPEARANCE
ON BEHALF OF THE PLAINTIFF CALL CENTER TECIHNOLOGIES, INC.
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Pursuant to Local Rule 7(e) ofthe United States District Court, District of Connecticut, Local
Rules of Civil Procedure ("Local Rules") Attorney Jack D. Garamella, on behalf of the law firm of
Collins, Hannatin, Garamella, Jaber & Tuozzolo, P.C. respectfully reqiiests permission to withdraw
as counsel for the Plaintiff Call Center Technologies, Inc. in the above referenced matter. I
The Plaintiff in this case has failed to cooperate with counsel regarding conducting discovery
and the Plaintiff has failed to cooperate with counsel regarding answering Defendant Interline Travel
& Tour, Incfs interrogatories. The Plaintiffs failure to cooperate with counsel continues despite
II repeated written requests and phone calls from counsel asking the Plaintiff to provide information
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. , Case 3:03-cv-010565DJS Document 36 Filed 05/%8$OO4 Page 2 of 4 i
regarding discovery, a large part of which was to take place in Texas, and that the Plaintiff answer
· Defendant lnterline Travel & Tour, lnc.’s interrogatories. i
The Plaintiffs failure to cooperate and communicate with counsel has made it impossible for
counsel to provide any kind of` effective representation to the Plaintiff \
The Plaintiff has been sent acopy of this Motion to Withdraw by doth certified and regular mail
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and has been notified of the need to engage successor counsel in the event this motion is granted.
Jack D. Garamella, on behalf of the law firm of Collins, Hannafin, Garamella, Jaber &
Tuozzolo, P.C., therefore respectfiilly requests permission of the Court to have his appearance
withdrawn as counsel for the Plaintiff in this matter.
Dated this 27th day of May, 2004. I I
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PLAINTIFF
CALL CENTER TECHNOLOGIES, INC.
By ·· `· ”""
J ck . G ram , i
.. Ili s,.HannaIin, Gammella,
Jaber & Tunzzoleg P.C. \
M8 Deer Hill Avenue _ _
Danbury, CT 068l0· .
Telephone; (203) 744-2i50 -
Federal Bar [D CT @5973
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.. , A Case 3:03-cv-O10536\DJS Document 36 Filed 05/Y28/$004 Page30f4 I
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ORDER - i
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The foregoing Motion having been heard by this Court, it is hereby ORDERED:
GRANTED/DENIED, l
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. .. _ Case 3:03-cv-O10é%6¤lDJS Document 36 Filed 05/28/2004 Page 4 of 4
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CERTIFICATION _
This is to certify that a copy ofthe foregoing was mailed, postaige prepaid on May 27, 2004,
to the Following: E
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Laura F. Baldini, Esquire ‘
2 Batterson Park Road _
2‘“' Floor | I
Farmington, CT 06032
Call Center Technologies, Inc.
632--640 Federal Road
Brookfield. CT 06804 ·—
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