United States District Court, D. Nevada
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,
MOTION TO WITHDRAW AS ATTORNEYS OF RECORD FOR CGROWTH
CAPITAL, INC., WILLIAM M. WRIGHT, III, AND KEYSTONE FINANCIAL
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.
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.
Defendants will continue to be represented by attorney of
record Frederick C. Bauman.
OF POINTS AND AUTHORITIES
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.
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.
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