MDY Industries, LLC v. Blizzard Entertainment, Inc. et al

Filing 224

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M. Paul Fischer (I.D. No. 002579)
THE LAW FIRM OF

M. PAUL FISCHER, P.C.
SUITE 100 40 NORTH CENTER STREET P.O. BOX 5139 MESA, ARIZONA 85211-5139 [phone]

Attorneys for

Plaintiffs IN THE UNITED STATES DISTRICT COURT IN THE PHOENIX DIVISION, DISTRICT OF ARIZONA

PAUL LANCE RAMIREZ, Plaintiff, vs. ARIZONA PUBLIC SERVICE COMPANY, a Arizona Corporation d/b/a APS; ABC CORPORATIONS I-X; BLACK AND WHITE PARTNERSHIPS I-X; JOHN DOES I-X, Defendant.

No. CV04-2955-PHX-SRB

PLAINTIFF'S COUNSEL'S EX PARTE MOTION TO WITHDRAW AS ATTORNEY OF RECORD WITH CONSENT

M. Paul Fischer, Esq., with THE LAW FIRM OF M. PAUL FISCHER, P.C., is the attorney of record for the Plaintiff, PAUL LANCE RAMIREZ, in the above captioned matter. Undersigned counsel moves at this time for the Court to issue an order permitting him to withdraw as the attorney of record in this case pursuant to Local Rule 83.3(b)(1) United States District Court Rules. This request is made pursuant to the consent and agreement of the Plaintiff (See exhibit "1" attached hereto). The reason for this request to withdraw is because there has been a substantial breakdown in communication between undersigned counsel and Plaintiff that would make it impossible for undersigned counsel to proceed in representation of this case. It

Ramirez Motion to Withdraw with consent.doc

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would be in the best interests of the client to seek and obtain new counsel to proceed with this case. The case is currently scheduled for trial March 13, 2007. Plaintiffs have been notified in writing of the status of the case, pending compliance with any Court Orders, and the possibility of sanctions by way of correspondence dated August 3, 2006 (See exhibit "2" attached). All further correspondence should be directed to Plaintiffs at the last known address below: Paul Lance Ramirez 514 East Rockwood Drive Phoenix, AZ 85024 623 516 1231 WHEREFORE, undersigned counsel respectfully requests that the Court relieve it of any further responsibility in this matter by permitting The Law Firm of M. Paul Fischer, P.C., and M. Paul Fischer, Esq., to withdraw as Plaintiffs' counsel. DATED this 3rd day of August, 2006. THE LAW FIRM OF M. PAUL FISCHER, P.C.

By /s/ M. Paul Fischer (SBN 002579) M. Paul Fischer P.O. Box 5139 Mesa, Arizona 85211-5139 Attorneys for Plaintiff

Ramirez Motion to Withdraw with consent.doc

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 /s/ Kim Welcher

CERTIFICATE OF SERVICE I hereby certify that on the 3rd day of August, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF Systems for filing. and a COPY of the foregoing hand-delivered this date to: Paul Lance Ramirez 514 East Rockwood Drive Phoenix, AZ 85024

Ramirez Motion to Withdraw with consent.doc

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