Ashford et al v. East Coast Express Eviction et al

MOTION to Withdraw as Attorney For Plaintiff Harry J. Ashford

D.D.C.July 31, 2007

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ Harry Jakeyia Ashford, et al., ) ) Civil Action No. 06-cv-1561 (RJL) Plaintiffs, ) v. ) Hon. Richard J. Leon ) East Coast Express Eviction, et al., ) ) Defendants. ) ____________________________________) MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF HARRY J. ASHFORD Under Local Civil Rule of the United States District Court for the District of Columbia 83.6(c), undersigned counsel (“Plaintiffs’ Counsel”) hereby request that Court permit them to withdraw as counsel for plaintiff Harry Jakeyia Ashford in the above captioned matter. In support of this motion, undersigned counsel state as follows: 1. Plaintiffs’ Counsel has fully advised Mr. Ashford of the circumstances giving rise to their desire to withdraw from representing Mr. Ashford in this proceeding. 2. Mr. Ashford subsequently requested and consented to the termination of Plaintiffs’ Counsel’s representation of him. Mr. Ashford has informed Plaintiffs’ Counsel that he does not have another lawyer and has indicated to Plaintiffs’ Counsel that he intends to continue to pursue his claims on a pro se basis. 3. Permitting Plaintiffs’ Counsel to withdraw as counsel for Mr. Ashford will not cause undue delay, will not prejudice any parties, and will not contravene the interests of justice. No trial date has yet been set in this matter, and a trial schedule will therefore not be impacted if the Court grants this motion. There are no pending deadlines on plaintiffs, Case 1:06-cv-01561-RJL-JMF Document 108 Filed 07/31/2007 Page 1 of 4 and Mr. Ashford is aware of the next status conference in this matter, which is scheduled for August 17, 2007. Plaintiffs’ Counsel will provide to Mr. Ashford a complete copy of the case file for this matter, which will allow Mr. Ashford to take full advantage of the discovery and motions practice that has occurred in this case to date. Finally, allowing Plaintiffs’ Counsel to withdraw will give effect to Mr. Ashford’s desire to protect and pursue his own interests. For the reasons set forth above, Plaintiffs’ Counsel respectfully requests that the Court enter the accompanying proposed order an permit Plaintiffs’ Counsel to withdraw as counsel for Mr. Ashford. Dated: July 31, 2007 Respectfully submitted, /s/ Lee F. Berger Lee F. Berger (D.C. Bar # 482435) Matthew D. Slater (D.C. Bar # 386986) Larry C. Dembowski (D.C. Bar # 486331) Matthew J. Berman (D.C. Bar # 489242) Cleary Gottlieb Steen & Hamilton LLP 2000 Pennsylvania Avenue, N.W. Washington, DC 20006 Telephone: (202) 974-1500 Facsimile: (202) 974-1999 Attorneys for Plaintiffs Kirk Greene, Anthony Forte, Hassan Shakur, Sandy Green, Alvin Dozier and Donald Brooks 2 Case 1:06-cv-01561-RJL-JMF Document 108 Filed 07/31/2007 Page 2 of 4 CERTIFICATE OF SERVICE I, Lee F. Berger, hereby certify that: On July 31 2007, a copy of the foregoing Motion for Leave to Withdraw as Counsel for Plaintiff Harry J. Ashford, Proposed Order and Notice to Harry J. Ashford of Termination of Representation were served by electronic transmission through the Court’s CM/ECF System on the following parties: David E. Fox 1325 Eighteenth Street, N.W. Suite 103 Washington, D.C. 20036 davidefox@gmail.com Gina M. Smith Meyers, Rodbell & Rosenbaum, P.A. 6801 Kenilworth Avenue, #400 Riverdale Park, MD 20730 gsmith@mrrlaw.net and were served by U.S. mail, first-class postage prepaid, on the following parties: Lloyd J. Eisenberg Lloyd J. Eisenberg & Associates, P.A. 10632 Little Patuxent Parkway Suite 430 Columbia, MD 21044 Melvin L. Otey Law Offices of Melvin L. Otey, PLLC 3609 Georgia Avenue, N.W., Suite 200 Washington, D.C. 20010 East Coast Express Evictions 29 U Street, N.W. Washington, D.C. 20001 Nelson Terry 29 U Street, N.W. Washington, D.C. 20001 Platinum Realtor Services, Inc. 6705 McKeldin Drive Case 1:06-cv-01561-RJL-JMF Document 108 Filed 07/31/2007 Page 3 of 4 Suitland, MD 20746 Choya Lord Rodriguez 6705 McKeldin Drive Suitland, MD 20746 Crawford & Crawford 200 55th Street, N.E. Apt. # 24 Washington, D.C. 20019 Vincent Crawford 200 55th Street, N.E. Apt. # 24 Washington, D.C. 20019 Harry J. Ashford c/o Street Sense 1317 G Street, N.W. Washington, D.C. 20005 Dated: July 31, 2007 /s/ Lee F. Berger Lee F. Berger 2 Case 1:06-cv-01561-RJL-JMF Document 108 Filed 07/31/2007 Page 4 of 4