Tilton et al v. Francis et al

Filing 17

Tilton et al v. Francis et al

Doc. 17

Case 8:07-cv-00432-JSM-MAP

Document 17

Filed 07/03/2007

Page 1 of 3

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION JULIE TILTON, NICOLE BREITFELLER, and TABITHA GAUTREAUX, Plaintiffs, v. JOSEPH R. FRANCIS, MRA HOLDINGS, L.L.C., MANTRA FILMS, INC. d/b/a Girls Gone Wild, AMX PRODUCTIONS, L.L.C. d/b/a AMX Video a/k/a GM Video a/k/a George Martin Video a/k/a Action Matrix, a/k/a Aztec Media Co., and SVOTHI, INC. d/b/a PPVNetworks a/k/a Nakedontv.com Defendants. ____________________________________/ MOTION TO WITHDRAW AS COUNSEL The Solomon Tropp Law Group, P.A. ("Solomon Tropp"), co-counsel for Tabitha Gautreaux ("Gautreaux") and Julie Tilton ("Tilton"), hereby moves the Court, pursuant to Rule 2.03(b), Local Rules, Middle District of Florida, for an order permitting this firm to withdraw as co-counsel of record for Gautreaux and Tilton in this action. As grounds for this Motion, co-counsel states: 1. Richard S. Shankman, Esquire ("Shankman") has been counsel for CASE NO. 8:07-cv-00432-JSM-MAP

Gautreaux and Tilton for several years in this case. 2. Solomon Tropp was brought in to serve as co-counsel for the purpose of

acting as lead trial counsel in this and related cases.

17938.33003.278280

1
Dockets.Justia.com

Case 8:07-cv-00432-JSM-MAP

Document 17

Filed 07/03/2007

Page 2 of 3

3.

Shankman will continue to represent Gautreaux and Tilton's interests as

counsel in this action. 4. The demands of upon Solomon Tropp's practice make it impractical for

them to remain as co-counsel with Shankman in this case. 5. Because this case is in its infancy, Gautreaux and Tilton will not be

prejudiced by co-counsel's withdrawing from this action. 6. In accordance with Local Rule 2.03(b), the clients and opposing counsel

have had ten days notice of our intention to withdraw prior to the filing of this motion. 7. In accordance with Local Rule 3.01(g), the undersigned counsel has

attempted to confer with counsel of record for all remaining parties, and no objections were expressed. WHEREFORE, the Court should authorize The Solomon Tropp Law Group, P.A. to withdraw as counsel of record for Tabitha Gautreaux and Julie Tilton in this action. Respectfully submitted, /s/ Thomas E. DeBerg Thomas E. DeBerg Florida Bar No. 521515 [e-mail] THE SOLOMON TROPP LAW GROUP, P.A. 1881 West Kennedy Boulevard Tampa, Florida 33606-1606 [phone] (Tel) [phone] (Fax) Attorneys for Plaintiffs

17938.33003.275724v2

2

Case 8:07-cv-00432-JSM-MAP

Document 17

Filed 07/03/2007

Page 3 of 3

Certificate of Service I HEREBY CERTIFY on July 3, 2007 that a true and correct copy of the foregoing has been furnished via electronic service copy to the following:
Gary S. Edinger [e-mail] Law Office of Gary Edinger, P.A. 305 NE 1st Street Gainesville, FL 32601 Attorneys for Svothi, Inc. David B. Weinstein [e-mail] Sean P. Cronin [e-mail] Richard C. McCrea [e-mail] Kimberly Staffa Mello [e-mail] Greenberg Traurig, P.A. 625 E. Twiggs Street Suite 100 Tampa, FL 33602 Attorneys for Mantra Films, Inc. and Joseph R. Francis Barry Scott Richard [e-mail] Greenberg Traurig P.A. 101 E. College Ave. Tallahassee, FL 32302 Attorneys for Mantra Films, Inc. and Joseph R. Frances AMX Productions, LLC c/o Michael Chaussee, Registered Agent 1837 S. Nevada Ave., Box 261 Colorado Springs, CO 80906 Richard S. Shankman, Esquire [e-mail] Litigation Concepts, LLC 2536 NW 53rd St. Boca Raton, FL 33496-2204 Attorneys for Plaintiffs

MRA Holdings, LLC. c/o CT Corporation Systems Registered Agent 7666 E. 61st St. Suite 240 Tulsa, OK 74133

/s/ Thomas E. DeBerg Thomas E. DeBerg Florida Bar No. 521515 [e-mail] THE SOLOMON TROPP LAW GROUP, P.A. 1881 West Kennedy Boulevard Tampa, Florida 33606-1606 [phone] (Tel) [phone] (Fax) Attorneys for Plaintiffs

17938.33003.278280

3