1
1 .x · I` ;r··¤
I UNITED STATES DISTRICT COURT 11 1 ____
1 ******=¥=***>1==I<>k>2<=1=»k=k>z<>1==k*=z==I=»I=»==:==I<»I·»I=>I=»»·>e¤ 1" {
1 EUNICE SMITH, * CIVIL NO. 3:03-V-001336 {_ mg
1 ""‘â€"’W j ` ri, `&1Ԥi’i“ ‘
1 VS. *
°" 1
DEPARTMENT OF CORRECTION, * 1
ET AL * 1
Defendant * DECEMBER 30, 2003 I
=l=>l==l<=I==l==1=>l=>I¢>I<>l=>l<=l==!=>l<=l<>I=>l<>|¢=l==I==I=>l¢>l¢=l<=l==l<=k=!=>l==k>I=>l¢ 1
1
MOTION T0 WITHDRAW APPEARANCE 1
Pursuant to Rule 7(e) of the Local Rules of Civil Procedure, the undersigned 1
counsellor, Marc L. Glenn, hereby respectfully requests leave of court to withdraw his 1
appearance in the above-referenced matter. The plaintiff has indicated a desire to retain
new counsel. Copies of the correspondence to plaintiff’s proposed new counsel are
attached as Exhibits A & B. No reply has been received from Attorney Miniter or his
office to this date. Notice has been sent to the plaintiff, via certified mail, of the instant
1
Motion to Withdraw. Notice has been sent to the plaintiff, via certified mail, of the 1
instant Motion to Withdraw. Plaintiff is hereby notified that the failure to engage
successor counsel or file a pro Se appearance will result in the granting of the instant
Motion to Withdraw and may result in a dismissal or default being entered against her. 1
WHEREF ORE, the undersigned respectfully requests that he be allowed to
1
I withdraw his appearance from the instant matter. 1
I
ORAL AR G UMEN T IS NOT REQUESTED
1
-A................. . ...__..__..__,, _ _,,__,,
p p__pp__pp__ p ` I
__ir__i___ir__rr__ir__ir
gg, A--A............. . .......__..__.. _ _,,__,,
__pp__pp__pp ‘ I ·
· ase 3:03-cv-OO386CAWT Document 23 Filed 12/$(23303 Page 2 of 4
l
l 2
I e¤r{ @44% 6
Marc L. Gle
Law Office of !
W. Martyn Philpot, Jr., L.L.C.
409 Orange Street
New Haven, CT 06511
Tel. N6. (203) 624-4666 {
Federal Bar No. ct21369 l
1
1
CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing was mailed, postage i
prepaid, this date, to: Jane B. Emmons, AAG, Office ofthe Attorney General, 55 Elm
Street, P.O. Box 120, Hartford, CT 06141-0].20, and certified mai1 to Eunice ‘ 1
Smith, P.O. Box 4415, Hartford, CT 06147. {
Marc L. Glenn l
i
E
I
I
l
· l
l
l
n
__ ____ I
I .
I “ Case 3:03-cv-OO386CAyWT Document 23 Filed 12/3IJ%OO3 Page 3 of 4
I .-··' sa
LAW OFFICE OF w. Mmrvu PHILPOT} Ja.
ARC .
" W NIARTYN Prrrrror Ia., L. L. c. â€' L GLE""'
— II 409 ORANGE srnaer, New I-tAvEN, comnacncur 06611-6406 0* c°"“S°'* I
I PALMER Y. EPLEA, in I
TEL {206} 624-4666
I FAX (206) 624-5050
EMAIL: [email protected] I
I September 29, 2003 I
I Francis A. Miniter, Esq. I
I Miniter and Associates ` ‘ I
I 147 Charter Oak Avenue I
Hartford, CT 06106
Re: Eunice Smith v. Department of Correction
I
Dear Attorney Miniter: .
It is my understanding that Eunice Smith has contacted you concerning the taking over of I
all future legal representation of her interests in the above-referenced matter. In accordance with *
Revised Formal Opinion No. 31 ofthe Connecticut Bar Association Committee on Professional
Ethics, your office is obligated to hold in escrow all attorney’s fees generated in this matter until
such time as an agreement can be made concerning any fee dispute. Upon your receipt of this I
letter, kindly forward back to this office your agreement to the above. Once this has been .
received, the file will be copied and forwarded to your office promptly. .
I
Thank you for your professional courtesy in this matter.
Sincerely, l remain .
. I
tb I
W. Martyn Philpo Jr. I
l 2
WMP:sbk . I ‘
I
I
· EXHIBIT
i I •
I ‘ Case 3:03-cv—OO38Q¢Aj/VT Document 23 Filed 12/3}/2003 Page 4 of 4
LAW OFFICE or w. Manrvu m-nu.r>cm Jn. Q
,., msc .¤ ·
W MARTYN PHILPOTIQ Ia., L. L. o. L LE""' I
ll 409 onmce smear, New I-mwsw, comnacrncur com-cans PALMER
* ret may 624-4666
l mx (aca) 624-5050
p EMAIL: phi|p0t.{[email protected]
\ October 21, 2003
1
I 1
i Francis A. Miniter, Esq.
Miniter and Associates L ` I
147 Charter Oak Avenue I
Hartford, CT 06106 _
Re: Eunice Smith v. De artment of Correction "
Dear Attorney Miniter: i
I am writing as a fo1low—up to my September 29, 2003 letter to you concerning your i
‘ taking over of the above-referenced tile. Please advise as to your position with respect to this I
matter. Upon your forwarding a letter indicating you will hold all attorney’s fees generated in
connection with this matter in escrow until we have agreed upon a reasonable fee distribution, I
will forward the file. I
1
- I look forward to hearing from you. `
Sincerely, I remain
WMP:sbl< . , t
EXHIBIT Z
r __.6.. l
·- _“-LW I
United States Free Forms
Canada Free Forms
United Kingdom Free Forms
Australia Free Forms