Rock N' Roll Foods, LLC et al v. Frazer et al

Filing 58

ORDER Granting 57 Motion to Withdraw as Attorney. Attorney Ryan A. Andersen withdrawn from the case. Signed by Magistrate Judge Daniel J. Albregts on 10/18/2023. (Copies have been distributed pursuant to the NEF - ALZ)

Case 2:15-cv-00988-JAD-DJA Document 58 Filed 10/18/23 Page 1 of 3

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ANDERSEN LAW FIRM, LTD.
Ryan A. Andersen, Esq.
Nevada Bar No. 12321
Email: [e-mail]
3199 E. Warm Springs Road, Suite 400
Las Vegas, NV 89120
Phone: [phone]
Fax: [phone]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Rock N’ Roll Foods, LLC; Richard “Rocky”
Parks,
Plaintiffs,
v.

Case No. 2:15-cv-00988-JAD-DJA
MOTION AND PROPOSED ORDER TO
WITHDRAW AS COUNSEL OF RECORD

Stephen Frazer; Emerging Technology
Corporation; et al.,
Defendants.

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RYAN A. ANDERSEN, ESQ., respectfully moves this court for an order permitting RYAN A.

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ANDERSEN, ESQ. (“Mr. Andersen”) who has appeared in these proceedings, to withdraw as counsel

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for Plaintiffs, ROCK N’ ROLL FOODS, LLC and RICHARD “ROCKY” PARKS (“Plaintiffs”), in the

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above captioned matter, pursuant to Local Rule IA 10-6, S.C.R 46, and N.R.C.P. 1.16(b)(1) and (7).

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This Motion is made and based upon the following Memorandum of Points and Authorities

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submitted herein, the Declaration of Ryan A. Andersen, Esq., the pleadings and papers on file herein,

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and any argument at the hearing of this Motion to Withdraw as Counsel of Record.

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Dated this 11th day of October, 2023.
Respectfully submitted by:
ANDERSEN LAW FIRM, LTD.
By:

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/s/ Ryan A. Andersen
Ryan A. Andersen, Esq.
Nevada Bar No. 12321
3199 E Warm Springs Road, Suite 400
Las Vegas, Nevada 89120

Case 2:15-cv-00988-JAD-DJA Document 58 Filed 10/18/23 Page 2 of 3

DECLARATION

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I, RYAN A. ANDERSEN, ESQ., declare under penalty of perjury, that the following is true
and correct:
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I am an attorney at law admitted to practice in all courts of the State of Nevada. I have

personal knowledge of the facts set forth below and I believe them to be true. I am over eighteen years
old, and I am competent to testify to the matters set forth herein.
2.

I represented, ROCK N’ ROLL FOODS, LLC and RICHARD “ROCKY” PARKS, in

the capacity of attorney, in the above referenced matter from filing date of my substitution of attorney
on until shortly after the case closed a little over six years ago.
3.

I currently do no represent ROCK N’ ROLL FOODS, LLC and RICHARD “ROCKY”

PARKS, as counsel or in any capacity, on any pending matters before this Court.
Dated this 11th day of October, 2023
ANDERSEN LAW FIRM, LTD.
/s/ Ryan A. Andersen
RYAN A. ANDERSEN, ESQ.
Nevada Bar No. 12321
3199 E Warm Springs Road. Suite 400
Las Vegas, NV 89120

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MEMORANDUM OF POINTS AND AUTHORITIES
Mr. Andersen’s representation of the Plaintiffs came to an end shortly after this case closed a
little over six years ago. As such, undersigned counsel no longer represents the Plaintiffs in any capacity.
The Local Rule IA 10-6(a) provides that “No attorney may withdraw after appearing in a case except by
leave of court after notice served on the affected client and opposing counsel.” The Plaintiffs and
opposing parties in this case will receive notice of this Motion to Withdraw, pursuant to the Certificate
of Service herein.

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Additionally, Local Rule IA 10-6(e) provides that “no withdrawal… shall be approved if delay
of discovery, the trial, or any hearing in the case would result.” Here, no delay of any kind will result
from Mr. Andersen’s withdrawal because Plaintiffs’ judgment has been entered and this case closed a

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Case 2:15-cv-00988-JAD-DJA Document 58 Filed 10/18/23 Page 3 of 3

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little over six years ago. Thus, Mr. Andersen’s withdrawal will not prejudice any party or delay any

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proceeding in this matter.

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CONCLUSION

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For the reasons set forth above, Mr. Andersen respectfully moves this Court to enter an Order
Approving the withdrawal of Mr. Andersen as attorney for ROCK N’ ROLL FOODS, LLC and
RICHARD “ROCKY” PARKS in the instant matter.
Date this 11th day of October, 2023.
ANDERSEN LAW FIRM, LTD.
/s/ Ryan A. Andersen
RYAN A. ANDERSEN, ESQ.
Nevada Bar No. 12321
3199 E Warm Springs Road, Suite 400
Las Vegas, NV 89120

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CERTIFICATE OF SERVICE

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Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 11th day of
October, 2023, I caused the MOTION AND PROPOSED ORDER TO WITHDRAW AS COUNSEL
OF RECORD and the DECLARATION OF RYAN A. ANDERSEN, ESQ., IN SUPPORT OF THE
MOTION TO WITHDRAW AS COUNSEL OF RECORD to be served by the Court’s CM/ECF
system. The above-named documents were also served to the following via U.S. Regular Mail:
Richard “Rock” Parks
2766 Duneville St
Las Vegas, NV 89146

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Rock N’ Roll Foods, LLC
2766 Duneville St
Las Vegas, NV 89146
/s/ Melissa Rodriguez
Melissa Rodriguez, an employee
of Andersen Law Firm, Ltd.

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IT IS SO ORDERED.

IT IS SO ORDERED

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10/18/2023
Dated: __________________

____________________________________
UNITED STATES MAGISTRATE JUDGE
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