Free Motion for Hearing - District Court of Connecticut - Connecticut

Case 3:01-cv-02158-WWE

Document 47

Filed 03/26/2004

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT * * * * * * * * * * * * * * * * * * DONALD WAINRIGHT, JANET * WAINRIGHT, and DEBORAH * Case No.:301-CV-2158 RUSSO-WILLIAMS, * Plaintiffs, * * v. * * OSM COMMUNICATIONS, INC., * ISRAEL POLANSKY, ROBERT POLANSKY* ANNE POLANSKY * MARCH 25, 2004 Defendants * * * * * * * * * * * * * * * * * *

DEFENDANTS' COUNSEL'S RENEWED MOTION TO WITHDRAW AND REQUEST FOR HEARING

The

undersigned Inc.

counsel

for

the and

Defendants, Robert

OSM

Communications,

("OSM"),

Polansky

("Polansky"), pursuant to Local FRCP, Rule 15, hereby renews its Motion to Withdraw as counsel for OSM and Polansky the Defendants in this action on the grounds that the client has failed to comply with the Court's Order regarding the payment of counsel's reasonable attorney's fees in that no payment at all has been received to by date despite on the necessity of OSM for and

continuing Polansky.

activities

counsel

behalf

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Case 3:01-cv-02158-WWE

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WHEREFORE, the Motion to Withdraw is renewed and should be granted. PLAINTIFF, OSM COMMUNICATIONS, INC., ET AL. By______________________ Richard C. Feldman, Esq. Evans, Feldman & Boyer, LLC 261 Bradley Street P.O. Box 1694 New Haven, CT 06507-1694 (203)772-4900 (203)782-1356 fax [email protected] fed bar#ct5931 By__________________________ Keith R. Ainsworth, Esq. Evans, Feldman & Boyer,LLC 261 Bradley Street P.O. Box 1694 New Haven, CT 06507-1694 fax(203)772-4900 (203)782-1356 [email protected] fed bar #ct8118

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT * * * * * * * * * * * * * * * * * * DONALD WAINRIGHT, JANET * WAINRIGHT, and DEBORAH * Case No.:301-CV-2158 RUSSO-WILLIAMS, * Plaintiffs, * * v. * * OSM COMMUNICATIONS, INC., * ISRAEL POLANSKY, ROBERT POLANSKY* ANNE POLANSKY * , 2004 Defendants * * * * * * * * * * * * * * * * * * ORDER WHEREAS, Defendants' counsel's Motion to Withdraw, OSM Communications, Inc., and Robert Polansky, was presented to the Court; and WHEREAS, the Court ordered that counsel remain as counsel for the Defendants Robert Polansky and OSM Communications, Inc., contingent upon the clients paying counsels' reasonable attorneys fees; and WHEREAS, Robert Polansky and OSM Communications, Inc. have failed to make any payments, it appears that there is good cause to grant this Motion; IT IS ORDERED that counsel for the Defendants may withdraw from representation upon notification to the Defendants of this order. Dated this Connecticut. _ day of _______, 2004 at Bridgeport,

________________________________________ , U.S. District Court Judge

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CERTIFICATION THIS IS TO CERTIFY that a copy of the foregoing mailed, postage prepaid, this 25th day of March, 2004 to: was

Robert E. Arnold, Esq., Law Offices of Robert E. Arnold, Esq.,for Donald Wainright, Janet Wainright, Deborah RussoWilliams, 412 Orange Street, New Haven, CT 06511. Michael Sulzbach, Esq., for Ann Polansky and Israel Polansky, 385 Orange Street, New Haven, CT 06511-6406 And sent certified mail, return receipt requested, to Robert Polansky and OSM Communications, Inc., 3 East 69th Street, Apartment 2A, New York, NY 10021 and by e-mail to [email protected]. _____________________ Keith R. Ainsworth

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