Securities and Exchange Commission v. Nadel et al
MOTION for John A. Rine to withdraw as attorney by Jeff Downey, Paul Downey, Quest Energy Management Group, Inc.. (Rine, John)
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
SECURITIES AND EXCHANGE
ARTHUR NADEL; SCOOP CAPITAL, LLC;
and SCOOP MANAGEMENT, INC.,
Case No: 8:09-cv-87-T-26TBM
SCOOP REAL ESTATE, L.P.; VALHALLA
INVESTMENT PARTNERS, L.P.;
VALHALLA MANAGEMENT, INC.;
VICTORY IRA FUND, LTD.; VICTORY
FUND, LTD.; VIKING IRA FUND, LLC;
VIKING FUND, LLC; and VIKING
MOTION FOR LEAVE TO WITHDRAW AS COUNSEL
FOR PAUL DOWNEY AND JEFF DOWNEY
The Law Firm of Lewis Brisbois Bisgaard & Smith, LLP and its attorneys hereby
move the Court for leave to withdraw as counsel for Paul Downey and Jeff Downey (the
“Downeys”), in the above-styled matter and to have their names removed from the service
list in this matter and be relieved of all further responsibilities to the Downeys in this matter.
Irreconcilable differences have arisen between the Downeys and undersigned cousenl
necessitating the withdrawal of counsel from this case.
Counsel have good cause to make this motion, and circumstances have arisen that
prevent them form continuing to represent the Downeys and that permit them to withdraw in
accordance with Rule 4-1.16(b) of the Florida Rules of Professional Conduct. Counsel have
advised the Downeys that they will seek leave to withdraw from this action. The Downeys
have advised that they consent to the withdrawal.
For the reasons set forth in this motion, Counsel respectfully request that the Court
enter the proposed order submitted herein.
LEWIS BRISBOIS BISGAARD & SMITH LLP
s/John A. Rine
JOHN A. RINE
Florida Bar Number 989400
Florida Bar Number 339334
3812 Coconut Palm Drive, Suite 200
Tampa, Florida 33619-1352
Phone: 813.739.1900; Fax: 813.739.1919
Attorneys for Paul Downey and Jeff Downey and Quest
Management Group, Inc.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 21st day of October, 2014, I electronically filed the
foregoing with the Clerk of Court by using the CM/ECF system, which will send a notice of
electronic filing to all counsel of record.
s/John A. Rine
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