MORT et al v. LAWRENCE COUNTY CHILDREN AND YOUTH SERVICES et al

Filing 47

MOTION to Withdraw as Attorney the appearance of Quinn A. Johnson by ELIZABETH MORT, ALEX RODRIGUEZ. (Attachments: # 1 Proposed Order) (Oliver, Antoinette)

888232. i

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYL VANIA
ELIZABETH MORT and ALEX
RODRIGUEZ,

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Plaintiffs,
v.

LAWRENCE COUNTY CHILDREN AND
YOUTH SERVICES; LAWRENCE
COUNTY; CHRISSY MONTAGUE,
Lawrence County Children and Youth
Services Caseworker; and JAMESON
HEALTH SYSTEM, INC.
Defendants.

Civil Action No. 2:1O-cv-01438-DSC

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MOTION FOR LEAVE TO WITHDRAW APPEARANCE
Pursuant to Local Rule 83.2.(C)(4), the undersigned counsel hereby moves this Court for

leave to withdraw the appearance of Quinn A. Johnson, Esquire, in this case as counsel for

Plaintiffs Elizabeth Mort and Alex Rodriguez, (hereinafter collectively referred to as
"Plaintiffs"). In support of this motion, the undersigned counsel avers as follows:
1. Attorney Johnson is no longer associated with the law firm of Meyer, Unkovic &

Scott LLP.
2. Plaintiffs are represented by other counsel in this matter from the law firm of

Meyer, Unkovic & Scott LLP and from the American Civil Liberties Foundation of
Pennsylvania.
3. Plaintiffs wil not suffer any prejudice through the withdrawal of Attorney

Johnson.

4. The withdrawal of Attorney Johnson will not delay the trial in this matter.

888232. i

WHEREFORE, the undersigned counsel respectfully requests this Court to withdraw the
appearance of

Quinn A. Johnson, Esquire, from this case.

MEYER, UNKOVIC & SCOTT LLP

By: Isl Antoinette Oliver
Patricia L. Dodge
PAID No. 35393
Antoinette Oliver
PA ID No. 206148
535 Smithfeld Street
Suite 1300
Pittsburgh, P A 15222-2315
[phone]

pld(imuslaw.com
aco(imuslaw.com
Sarah J. Rose

PAID No. 204936
Witold J. Walczak
PAID No. 204936
AMERICAN CIVIL LIBERTIES
FOUNDATION OF PENNSYLVANIA
313 Atwood Street
Pittsburgh, PA 15213
[phone]
srose(iaclupgh.org
vwalczak(iaclupgh.org
Counsel for Plaintiffs

-2-

888232. i

CERTIFICATE OF SERVICE
The' undersigned hereby certifies that a true and correct copy of the within Motion for

Leave to Withdraw Appearance was served this 15th day of September, 2011, via the Cour's
electronic transmission facilities pursuant to Fed. R. Civ. P. 5(b)(3) and Local Rule 5.5 upon the
following:

John C. Conti, Esquire
Richard J. Kabbert, Esquire
Dickie, McCamey & Chilcote
Two PPG Place, Suite 400
Pittsburgh, PA 15222
(Counsel for Defendant Jameson Health System, Inc.)

Mare Milie Jones, Esquire
Meyer, Daragh, Buckler, Bebenek & Eck, P.L.L.C.

U.S. Steel Tower, Suite 4850
600 Grant Street
Pittsburgh, PA 15219
(Counselfor Defendants Lawrence County Children and Youth Services, Lawrence County and
Chrissy Montague)

Isl Antoinette C. Oliver