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

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Angela M. Wilson-Goodman State Bar No. 017558 WILSON-GOODMAN & FONG, P.C. 538 S. Gilbert Road, Suite 101 Gilbert, Arizona 85296 (480) 503-9217 Fax: (480) 503-9219 Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA MARY CSANYI, Plaintiff, vs. REGIS CORPORATION; SUPER CUTS, Defendants. ) ) ) ) ) ) ) ) ) ) ) Case No.: CV-03-1987-PHX-JAT SECOND AMENDED MOTION TO WITHDRAW AS ATTORNEY OF RECORD

The law firm, WILSON-GOODMAN & FONG, P.C. by and through Angela M. Wilson-Goodman, attorney for Plaintiff, Mary Csanyi, hereby moves the Court pursuant to D. Ariz. L.R.Civ. 83.3(b)(2) for permission to withdraw as counsel of record for Plaintiff, MARY CSANYI, in this matter for the following reasons: 1. The Plaintiff has requested that undersigned counsel cease any further work

on her behalf on both this case and the appeal. 2. The Plaintiff has failed substantially to fulfill her obligations to the above

named attorney regarding payment of fees for services and has been given ample opportunity to make such payments. 3. Withdrawal by this attorney will have no adverse effect on the interest of

the client. Plaintiff has been notified in writing of the status of this case, including the

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dates and items of any Court hearing or trial settings, pending compliance with any existing court orders and the possibility of sanctions. Plaintiff has been notified in writing of the pending Motion for Attorneys' Fees filed by Defendant. 4. WILSON-GOODMAN & FONG, P.C. further advises the Court that

Plaintiff's address and phone number are: 8627 E. Northland Drive, Scottsdale, Arizona 85251, (480) 946-0410. WHEREFORE, Angela M. Wilson-Goodman, respectfully requests that the Court permit her to withdraw as attorney of Record for the Plaintiff, MARY CSANYI, for all reasons stated above.

CERTIFICATION Undersigned counsel hereby certifies that the Plaintiff has been notified in writing of the status of the case, including the dates and items regarding the appeal period. Furthermore, Plaintiff was mailed a copy of Defendants' Motion for Attorney's Fees on July 19, 2006, and has been provided with a copy of the Plaintiff's Response to Defendant's Motion for Attorney's Fees filed on her behalf on August 14, 2006. Plaintiff is aware of her responsibility over any additional proceedings.

RESPECTFULLY SUBMITTED this 29th day of August, 2006. WILSON-GOODMAN & FONG, P.C.

__/s/ Angela M. Wilson-Goodman Angela M. Wilson-Goodman 538 S. Gilbert Road, Suite 101 Gilbert, Arizona 85296 Attorney for Plaintiff

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CERTIFICATE OF SERVICE I hereby certify that on the 29th day of August, 2006, I electronically transmitted the attached Second Amended Motion to Withdraw as Attorney of Record to the U.S. District Court Clerk's office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: [email protected] [email protected]

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I hereby certify that on the 29th day of August, 2006, I served the attached Second Amended Motion to Withdraw as Attorney of Record by mail on the following, who is a registered participant in the CM/ECF System, but requested a paper copy: The Honorable James A. Teilborg United States District Judge Sandra Day O'Connor U.S. Courthouse, Suite 523 401 West Washington Street, SPC 51 Phoenix, AZ 85003-2154 I hereby certify that on the 29th day of August, 2006, I served the attached Second Amended Motion to Withdraw as Attorney of Record by mail on the following: Mary Csanyi 8627 E. Northland Drive Scottsdale, AZ 85251 Plaintiff /s/ Kim Johnson

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