Free Letter - District Court of Delaware - Delaware

Case1:O4-cv-01422-GIVIS D0cument1OO Filed O9/10/2007 Page1of3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
From: Mr. Jerome K. Hamilton,a/k/a
Cheikh Ahmed Elohim
Plaintiff:
320 East Fifth Street/Apt.609
Wilmington, Delaware.19801 no g
Dated: September 5,2007 QEE Iswsz
K (T
1 2,4;*1
TO: ____
Honorable Judge Gregory M. Sleet Q; §§§
United States District Court for the District of Delaware °° if
Lock Box 19
844 North King Street
Wilmington, Delaware.l9801
RE: Hamilton/Elohim v. Guessford, et al.
0.2:.. N0.04—1422—(sMs).
Dear Honorable Judge Gregory M. Sleet:
I am writing you this letter to report my concerns —
and position pertaining to plaintiff stipulation of dismissal.
1. Plaintiff/Jerome K. Hamilton, did received from a —
document on June 7,2007 by Mr. Gary W. Aber, requesting the Court permission
to withdraw as counsel for the plaintiff. Because of irreconsilable differe-
—nce and ethical reasons to continue to represent the plaintiff. See:(Attac—
-hed Exhibit- "A").
2. Plaintiff/Jerome K. Hamilton, is requesting this Hon-
—orable Court to be heard in open court on record, plaintiff version concerns
issue of stipulation of dismissal which is so important.
Thank you for Your Honor's consideration.
, tf ll _S b 'tt d
CC: Gary W. Aber,Esqu1re E
Eileen Kelly,E5quire Plaintiff/Jerome K. Hamilton
—a/k/a-Cheikh Ahmed Elohim
320 East Fifth Street/Apt.609
Wilmington, Delaware.1980l

Case 1 :04-cv—01422-GIVIS Document 100 Filed 09/10/2007 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
F OR THE DISTRICT OF DELAWARE
JEROME K. HAMILTON, a/k/a :
ELOI-{IM CHEIKH AHMED, :
Piamarr, 2
: C.A. No. 04—l422 (GMS)
V- IURY TRIAL DEMANDED
CATHY L. GUESSFORD, REBECCA 2 H
MCBRIDE, ROBERT F. SNYDER, THOMAS : gif
L. CARROLL, and STANLEY W. TAYLOR, : ;
JR. r or if
Defendants
MOTION TO WITI-IDRAVV
The undersigned, counsel for the plaintiff in the above-captioned matter moves this Court for
permission to withdraw from representation in this matter.
The basis for this motion is as follows:
I. The plaintiff in this matter initially consulted with the undersigned to represent him in
the above—captioned matter. The undersigned drafted a complaint for the plaintiff. Differences
arose following the drafting of that complaint, and the plaintiff discharged the undersigned.
2. The plaintiff filed the complaint drafted by the undersigned pro se.
3. At a time thereafter, the plaintiff approached the undersigned again asking him to
reconsider taking up his representation of him. The undersigned agreed to reassunie the
representation of the plaintiff.
4. This matter has proceeded through discovery, and up to the stage of the defendant filing
a motion for summary judgment.
5. The undersigned has conducted numerous negotiations with defense counsel, and in
continual consultation with the plaintiff As a result on May 31, 2007 the plaintiff agreed to settle
the above-captioned litigation.
Exhibit- "A"

Case 1:04-cv-01422-Gl\/IS Document 100 Filed 09/10/2007 Page 3 of 3
6. On June 5, 2007 irreconsilable difference arose between the plaintiff and the
undersigned, t0 the extent that the undersigned does not believe he can ethically continue to
represent the plaintiff.
WHEREFORE, the undersigned requests the Court permission to withdraw as counsel for the
plaintiff.
ABER, GOLDLUST, BAKER & OVER 1
/s/ Gary W. Aber
GARY W. ABER (DSB #754)
702 King Street, Suite 600
P.O. Box 1675
Wilmington, DE 19899
302—472—4900
DATED; June 7, 2007 Attorney for Plaintiff
EXl'1i.bZl.‘l:- "A"
2