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Filing# 184908038 E-Filed 10/27/2023 12:12:42 PM
101172-7
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
JENNIFER BRADLEY, individually, CIRCUIT CIVIL DIVISION
and JENNIFER BRADLEY
CORPORATION, INC. a Florida CASE NO. CACE-21-010368
Corporation,
Plaintiff.
VS.
WILLIAM BROWNING, individually,
and BROWNING PRODUCTIONS
AND ENTERTAINMENT, INC., a
Florida Corporation,
Defendant.
i
PLAINTIFF COUNSEL'S MOTION TO WITHDRAW FROM REPRESENTATION OF
JENNIFER BRADLEY AND JENNIFER BRADLEY CORPORATION, INC.
COMES NOW, Plaintiff's Counsel, WICKER SMITH O'HARA MCCOY & FORD,
P.A. ("Wicker Smith"),by and through the undersignedcounsel, serves this Motion to Withdraw
as Counsel for the Plaintiffs Jennifer Bradley and Jennifer Bradley Corporation,Inc. (collectively
due to irreconcilable differences arisingfrom the bankruptcy of the Plaintiffs.
the "Plaintiffs")
1. Wicker Smith began representation
of the Plaintiffs by filingthe complaint at issue in this
disputeon May 24,2021. See generally Plaintiffs' complaint.
2. that Wicker Smith withdraw as
Since that time, the situation has changed necessitating
counsel to the Plaintiffs.
3. Under the Rules Regulating the Florida Bar,
[A] lawyer may withdraw from representinga client if: (1)
withdrawal can be accomplishedwithout material adverse effect on
the interests of the client;(2) the client insists upon taking action
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/27/2023 12:12:42 PM.****
CASE NO. CACE-21-010368
that the lawyer considers repugnant, imprudent, or with which the
lawyer has a fundamental disagreement; (3) the client fails
substantially to fulfill an obligationto the lawyer regarding the
lawyer'sservices and has been given reasonable warning that the
lawyer will withdraw unless the obligationis fulfilled;(4) the
representation will result in an unreasonable financial burden on
the lawyer or has been rendered unreasonably difficult by the
client;or (5) other good cause for withdrawal exists.
R. Regul. FL. Bar 4-1.16.
4. Irreconcilable differences have arisen,including both Plaintiffs having filed for bankruptcy
without any advance notice to the undersigned firm.
5. Regarding Jennifer Bradley Corporation,Inc., counsel for the Trustee, acting for the
Company, has advised that the Company has no interest in pursuing this case.
6. the
Regarding Jennifer Bradley,individually, last direct communication occurred on or about
April 20,2022, and irreconcilable differences have arisen as referenced above.
7. Accordingly, any requirement that Wicker Smith continue representationin this matter will
result in an unreasonable financial burden to Wicker Smith.
directly
8. The undersigned have acted in good faith regarding its decision to file this motion to
withdraw and have activelycommunicated with Plaintiffs' Bankruptcy Trustee and attempted
to communicate with Jennifer Bradley,individually,
regardingthis matter.
9. The Plaintiffs' last known address, telephone number, and email addresses are as follows:
a. Jennifer Bradley:
i. 5371 NE 17t'th
Terrace, Fort Lauderdale, FL 33334
ii. (954) 647-4819
iii. com
jennifer@jenniferbradley.
-2-
CASE NO. CACE-21-010368
b. Jennifer Bradley Corporation,Inc.
i. 4401 W. Tradewinds Ave Second Floor Lauderdale By The Sea, FL 33308
ii. (954) 383-5186
iii. jenniferbradleyco@gmail.com
WHEREFORE, requests this Honorable Court grant
the undersigned counsel respectfully
this Motion to Withdraw as counsel to the Plaintiffs.
WE HEREBY CERTIFY that a copy hereof has been electronically
served via Florida
ePortal to: Peter A. Koziol, Esquire,pak@assoulineberlowe.corn;
ja@assoulineberlowe.com;
Eric N. Assouline, Esquire,ena@assoulineberlowe.com;ah@assoulineberlowe.com;Barry P.
Gruher, Esquire,bpgruher@venable.com; Avi Zemel, Esquire,azemel@venable.com; on this
27th day o f October, 2023.
/s/ Garrett Moon
Jordan S. Cohen, Esquire
Florida Bar No. 551872
Garrett M. Moon, Esquire
Florida Bar No. 1048513
WICKER SMITH O'HARA MCCOY & FORD, P.A.
Attorneys for Jennifer Bradley and Jennifer Bradley
Corporation,Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft.Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
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Preview
Filing# 184908038 E-Filed 10/27/2023 12:12:42 PM 101172-7 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JENNIFER BRADLEY, individually, CIRCUIT CIVIL DIVISION and JENNIFER BRADLEY CORPORATION, INC. a Florida CASE NO. CACE-21-010368 Corporation, Plaintiff. VS. WILLIAM BROWNING, individually, and BROWNING PRODUCTIONS AND ENTERTAINMENT, INC., a Florida Corporation, Defendant. i PLAINTIFF COUNSEL'S MOTION TO WITHDRAW FROM REPRESENTATION OF JENNIFER BRADLEY AND JENNIFER BRADLEY CORPORATION, INC. COMES NOW, Plaintiff's Counsel, WICKER SMITH O'HARA MCCOY & FORD, P.A. ("Wicker Smith"),by and through the undersignedcounsel, serves this Motion to Withdraw as Counsel for the Plaintiffs Jennifer Bradley and Jennifer Bradley Corporation,Inc. (collectively due to irreconcilable differences arisingfrom the bankruptcy of the Plaintiffs. the "Plaintiffs") 1. Wicker Smith began representation of the Plaintiffs by filingthe complaint at issue in this disputeon May 24,2021. See generally Plaintiffs' complaint. 2. that Wicker Smith withdraw as Since that time, the situation has changed necessitating counsel to the Plaintiffs. 3. Under the Rules Regulating the Florida Bar, [A] lawyer may withdraw from representinga client if: (1) withdrawal can be accomplishedwithout material adverse effect on the interests of the client;(2) the client insists upon taking action *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/27/2023 12:12:42 PM.**** CASE NO. CACE-21-010368 that the lawyer considers repugnant, imprudent, or with which the lawyer has a fundamental disagreement; (3) the client fails substantially to fulfill an obligationto the lawyer regarding the lawyer'sservices and has been given reasonable warning that the lawyer will withdraw unless the obligationis fulfilled;(4) the representation will result in an unreasonable financial burden on the lawyer or has been rendered unreasonably difficult by the client;or (5) other good cause for withdrawal exists. R. Regul. FL. Bar 4-1.16. 4. Irreconcilable differences have arisen,including both Plaintiffs having filed for bankruptcy without any advance notice to the undersigned firm. 5. Regarding Jennifer Bradley Corporation,Inc., counsel for the Trustee, acting for the Company, has advised that the Company has no interest in pursuing this case. 6. the Regarding Jennifer Bradley,individually, last direct communication occurred on or about April 20,2022, and irreconcilable differences have arisen as referenced above. 7. Accordingly, any requirement that Wicker Smith continue representationin this matter will result in an unreasonable financial burden to Wicker Smith. directly 8. The undersigned have acted in good faith regarding its decision to file this motion to withdraw and have activelycommunicated with Plaintiffs' Bankruptcy Trustee and attempted to communicate with Jennifer Bradley,individually, regardingthis matter. 9. The Plaintiffs' last known address, telephone number, and email addresses are as follows: a. Jennifer Bradley: i. 5371 NE 17t'th Terrace, Fort Lauderdale, FL 33334 ii. (954) 647-4819 iii. com jennifer@jenniferbradley. -2- CASE NO. CACE-21-010368 b. Jennifer Bradley Corporation,Inc. i. 4401 W. Tradewinds Ave Second Floor Lauderdale By The Sea, FL 33308 ii. (954) 383-5186 iii. jenniferbradleyco@gmail.com WHEREFORE, requests this Honorable Court grant the undersigned counsel respectfully this Motion to Withdraw as counsel to the Plaintiffs. WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida ePortal to: Peter A. Koziol, Esquire,pak@assoulineberlowe.corn; ja@assoulineberlowe.com; Eric N. Assouline, Esquire,ena@assoulineberlowe.com;ah@assoulineberlowe.com;Barry P. Gruher, Esquire,bpgruher@venable.com; Avi Zemel, Esquire,azemel@venable.com; on this 27th day o f October, 2023. /s/ Garrett Moon Jordan S. Cohen, Esquire Florida Bar No. 551872 Garrett M. Moon, Esquire Florida Bar No. 1048513 WICKER SMITH O'HARA MCCOY & FORD, P.A. Attorneys for Jennifer Bradley and Jennifer Bradley Corporation,Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 Ft.Lauderdale, FL 33301 Phone: (954) 847-4800 Fax: (954) 760-9353 ftlcrtpleadings@wickersmith.com -3-