Free Motion to Substitute Attorney - District Court of Arizona - Arizona

1 BEAUGUREAU, ZUKOWSKI _
& HANCOCK, P.C. _ · ‘
2 2111 East Highland Avenue
Suite 255
3 Phoenix, Arizona 85016
(602) 956-4438
4 Terrance L. Sims (#009566)
_ 5 E-mail: [email protected]
6 WILENCHIK & BARTNESS, P.C.
2810 North 3rd Street
7 Phoenix, Arizona 85004
8 Dennis I. Wilenchik (#005350)
E-mail: [email protected] e
9 Lawrence J. Felder (#019763)
10 E-mail: [email protected]
H Attorneys for Defendants
Bristol Inns, L.L.C. and Desiree Keithan
l2
13 IN THE UNITED STATES DISTRICTPCOURT
14 FOR THE DISTRICT OF ARIZONA
15
Best Western International, Inc., ) No. CV-04-661-PHX-DGC
16 an Arizona non-profit corporation, )
)
17 Plaintiff, ) APPLICATION FOR
18 ) WITHDRAWAL AND
vs. ) SUBSTITUTION OF COUNSEL
19 )
Bristol Inns, L.L.C., a Tennessee limited )
20 liability company; and Desiree Keithan, ) (Assigned to Hon. David G. Campbell)
2l )
Defendants. )
22 )
- 23 Defendants Bristol Inns, L.L.C. and Desiree Keithan, hereby request that their
24 former attorneys, Terrance L. Sims and the firm of Beaugureau, Zukowski & Hancock,
25
P.C. be allowed to withdraw from representing them in this matter, and that said
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Case 2:04-cv-00661-DGC Document 25 Filed 12/13/2005 Page 1 of 3

I I Defendants be allowed to substitute as their attorneys of record herein Dennis I.
2 Wilenchik, Lawrence J. Felder and the firm of Wilenchik & Bartness, P.C., pursuant to
3
LRCiv 83.3(b)(1) of the Rules of Practice of the United States District Court for the
4
5 District of Arizona. The reasons for such withdrawal and substitution are that the
withdrawing attorneys were engaged by Defendants for the limited ur ose of
6 _ P P
7 endeavoring to set aside the default judgment entered against Defendants herein, when
8 only a few days remained within which to file that motion. That purpose having been
`
accomplished, substitute counsel are in a better position to devote the time required for
10
continued representation of Defendants than is withdrawing counsel. This action has not
11
12 been set for trial.
13 The name, last known residence and last known telephone number of the client
14 Defendants are as follows:
15 Bristol Inns, L.L.C. (now Bristol Lodging Services, L.L.C.)
16 111 Holiday Drive
Bristol, Tennessee 37620
17 (423) 968-1101
18 Desiree Keithan
19 284 Bellehaven Drive 1
Bristol, Virginia 24201 .
20 (423) 968-1101
21 This application bears the written approval of the clients, and is accompanied by a
22 proposed written order. The withdrawing attorney will give prompt notice of the entry of
23 I
such order, together with the name, last known residence and last known telephone
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25 number of the clients, to the attorneys for Plaintiff Best Western International, Inc.
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Case 2:04-cv-00661-DGC Document 25 Filed 12/13/2005 Page 2 of 3

1 DATED this 13m day of December, 2005. A
2
3 WILENCHIK & BARTNESS BEAUGUREAU, ZUKOWSKI
· & HANCOCK, P.C.
4
5 By: /s/ Lawrencel Felder By: /s/ Terrance L. Sims ·
6 Lawrence J. F elder Terrance L. Sims
. 2810 North 3'd Street 2111 East Highland Avenue
7 Phoenix, Arizona 85004 Suite 255
8 Phoenix, Arizona 85016
9
APPROVED; _ -
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11 Bristol Inns, L.L.C. (now Bristol Lodging Services, L.L.C.)
12 By° . . lnll e _
Desiree Kerthan, its General Manager of Operations ·
13 {
14 . _ 1
.
I5 Desiree Keithan, personally ·
16 _
17 CERTIFICATE OF SERVICE
18 I hereby certify that on December 13, 2005 I electronically filed the foregoing
9 with the Clerk of the Court using the CM/ECF system, which will send notification of
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such filing to the following: Michael G. Helms, Esq., counsel for plaintiff.
21
23 /s/ Terrance L. Sims
Terrance L. Sims
24
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