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Wingen v. Ventrum Energy Corp.

United States District Court, D. Nevada

March 28, 2018

PHILIP WINGEN, et al., Plaintiffs,
v.
VENTRUM ENERGY CORP., et al., Defendants.

          BAUMAN LAW FIRM Frederick C. Bauman (Nev. Bar No. 8370), GARVEY SCHUBERT BARER Gary I. Grenley (Pro Hac Vice) Eryn Karpinski Hoerster (Pro Hac Vice), Attorneys for CGrowth Capital, Inc., William M. Wright, III, and Keystone Financial Management, Inc.

          MOTION TO WITHDRAW AS ATTORNEYS OF RECORD FOR CGROWTH CAPITAL, INC., WILLIAM M. WRIGHT, III, AND KEYSTONE FINANCIAL MANAGEMENT, INC.

         COMES NOW Gary I. Grenley and Eryn Karpinski Hoerster of the law firm of Garvey Schubert Barer and hereby moves to withdraw as attorneys for Defendants CGrowth Capital, Inc., Keystone Financial Management, Inc., and William M. Wright, III (“Defendants”) in the above-captioned matter.

         This motion is made and based upon the papers and pleadings on file herein, the following points and authorities, and Declaration of Eryn Karpinski Hoerster attached hereto.

         The Defendants will continue to be represented by attorney of record Frederick C. Bauman.

         IT IS SO ORDERED.

         MEMORANDUM OF POINTS AND AUTHORITIES

         The Court should grant Garvey Schubert Barer's application to withdraw as attorneys of record for Defendants CGrowth Capital, Inc., Keystone Financial Management, Inc. and William M. Wright, III pursuant to the Nevada Rules of Professional Conduct (“NRPC”) 1.16 and LR IA 11-6. As set forth in the Declaration of Eryn Karpinski Hoerster attached hereto, notice of Garvey Schubert Barer's motion to Withdraw was mailed to Plaintiffs and all Defendants on March 9, 2018, and Garvey Schubert Barer has good cause to withdraw.

         NPRC 1.16 provides, in pertinent part, that a lawyer may withdraw from representation where:

(1) Withdrawal can be accomplished without material adverse effect on the interests of the client;
. . .
(6) The representation will result in unreasonable financial burden on the lawyer or has been rendered unreasonably difficult by the client; or
(7) Other good cause exists for withdrawal.

NRPC 1.16(b).

         The attached Declaration of Eryn Karpinski Hoerster is incorporated herein by reference and establishes that good cause exists for the withdrawal of Garvey Schubert Barer as counsel for Defendants, and that the withdrawal can be ...


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