Al Falahi v. United States Citizenship and Immigration Services

Filing 43

ORDER Granting 40 Stipulation to Withdraw Attorney. Signed by Magistrate Judge Cam Ferenbach on 5/17/2019. (Copies have been distributed pursuant to the NEF - JQC)

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Amy Rose
Nevada Bar 12081
Lauren Kaufman
Nevada Bar 14677C
AMERICAN CIVIL LIBERTIES UNION OF NEVADA
601 South Rancho Dr. Suite B-11
Las Vegas, NV 89106
Telephone [phone]
Fax [phone]
Alexandra Chrysanthis
Nevada Bar 3231
PRUDHOMME LAW OFFICES
633 South 4th Street Suite 7
Las Vegas, NV 89101
[e-mail]
Telephone [phone]
Fax [phone]
Attorneys for Petitioner

UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MOHAMMAD AL FALAHI,
Petitioner,

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STIPULATION TO WITHDRAW AMY
ROSE AS ATTORNEY OF RECORD

vs.

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Case No.: 2:16-cv-02921

UNITED STATES CITIZENSHIP AND
IMMIGRATION SERVICE, an entity,
Respondent.

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Petitioner’s counsel, Amy Rose’s continued representation of Mohammad Al Falahi is
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no longer tenable as her permanent relocation to California has necessitated that she leave her

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position at the American Civil Liberties Union of Nevada.

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Amy Rose has good cause to withdraw as counsel under the Nevada Rules of
Professional Conduct 1.16(b), which provides that a lawyer may withdraw from representation

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where:
(1) Withdrawal can be accomplished without material adverse effect on the
Stipulation to Withdraw Amy Rose as Attorney of Record

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interests of the client;

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…

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(7) Other good cause exists
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The withdrawal of Amy Rose from this case can be accomplished without adverse effect

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on the interests of the client because Amy Rose’s withdrawal will not delay proceedings in this
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matter. The Petitioner, Mohammad Al Falahi and the current staff attorney at the ACLU of

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Nevada, Lauren Kaufman, have agreed to all current timelines pending in this action

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On May 15, 2019, Joseph Carilli, Jr., opposing counsel, stated that he did not oppose the
withdrawal of Amy Rose in the current matter.

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It is hereby stipulated and agreed that Amy Rose is no longer affiliated with the American

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Civil Liberties Union of Nevada, and as such, hereby withdraws her appearance in the above-

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captioned matter, and requests that: (1) her name be removed from any applicable service lists

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herein; and (2) that the Clerk terminate the delivery of all notices addressed to [e-mail]

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in the above captioned case.
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All other current attorneys of the record shall continue to receive all applicable notices.

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Dated this 16th day of May, 2019

Dated this 16th, day of May, 2019

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/s/ Amy Rose ______
Amy Rose
Counsel for the Petitioner

/s/ Lauren Kaufman______
Lauren Kaufman
Counsel for the Petitioner

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Dated this 15th, day of May, 2019

Dated this 15th, day of May, 2019

/s/ Mohammad Al Falahi_______________
Mohammad Al Falahi
Petitioner

/s/ Joseph Carilli_____
Joseph Carilli, Jr.
Counsel for the Respondent

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Stipulation to Withdraw Amy Rose as Attorney of Record
5-17-2019

CERTIFICATE OF SERVICE

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I hereby certify that on the 16th, day of May 2019, I caused to be served a true and

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correct copy of the Stipulation to Withdraw as Amy Rose as Attorney of Record to be served to

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all the parties listed below by U.S. mail postage pre-paid and through the Courts CM/ECF

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electronic filing system.

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JOSEPH F. CARILLI, JR.
N.H. Bar Identification No. 15311
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Telephone: [phone]
E-mail: [e-mail]

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__/s/ Tamika Shauntee_________________
An employee of the ACLU of Nevada

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Stipulation to Withdraw Amy Rose as Attorney of Record