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Filing # 82090990 E-Filed 12/13/2018 03:41:47 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY,
FLORIDA
U.S. BANK, N.A., SUCCESSOR TRUSTEE CASE NO.: CACE18002037
TO LASALLE BANK, NATIONAL
ASSOCIATION, ON BEHALF OF THE
HOLDERS OF BEAR STEARNS ASSET
BACKED SECURITIES I TRUST 2006-
HE10, ASSET-BACKED CERTIFICATES
SERIES 2006-HE10,
Plaintiff,
NORA DUNCAN AKA NORA JEAN
DUNCAN, ET AL.,
Defendants.
/
MOTION TO WITHDRAW AS CO-COUNSEL FOR PLAINTIFF
COMES NOW, McGlinchey Stafford (“McGlinchey”), in accordance with Florida Rule of
Judicial Administration 2.505, and hereby moves this Honorable Court to allow said law firm to
withdraw as co-counsel for the Plaintiff in the above-captioned matter and in support thereof, states
as follows:
1. McGlinchey filed a Notice of Appearance as Co-Counsel for the Plaintiff in this
case on or about May 5, 2018 for the purpose of handling a specific phase of the instant litigation.
2. The specific issue has now been successfully resolved. McGlinchey now seeks to
withdraw as co-counsel for the Plaintiff in this matter and be relieved of all duties and
responsibilities related to said representation in this action.
3. The law firm of Tromberg Law Group, 1515 South Federal Highway, Suite 100,
Boca Raton, FL 33432, eservice@tromberglawgroup.net with whom McGlinchey was co-counsel
in this case, shall remain and serve as counsel for the Plaintiff.
1244082.1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/13/2018 3:41:47 PM.****WHEREFORE, McGlinchey hereby requests that this Honorable Court allow McGlinchey
to withdraw as co-counsel for the Plaintiff in this matter, relieve McGlinchey from all further
obligations and responsibilities in this matter, and any such other relief this Court deems just and
proper.
Dated: December 13, 2018
1244082.1
Respectfully submitted,
McGLINCHEY STAFFORD
/s/ Ralph W. Confreda, Esq.
Ralph W. Confreda, Jr., Esq.
Florida Bar No. 85794
1 E. Broward Blvd, Suite 1400
Fort Lauderdale, FL 33301
Telephone: (954) 356-2513
Fax: (954) 333-3847
Primary E-Mail: rconfreda@meglinchey.com
Secondary E-Mail: August
jruiz@meglinchey.com
CO-COUNSEL FOR PLAINTIFFCERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, via
e-portal and/or U.S. mail as indicated below on this 13th day of December, 2018 to the following:
FAEQUA A. KHAN, ESQ.
14707 S. DIXIE HWY, STE. 101
MIAMI, FL 33176
DJONES@DLIONESLAW.COM
FKHAN@DLJONESLAW.COM
Counsel for Nora Duncan and Robert Duncan
MARIE FOX, ESQ.
TROMBERG LAW GROUP, P.A.
1515 SOUTH FEDERAL HIGHWAY, SUITE 100
BOCA RATON, FL 33432
ESERVICE@TROMBERGLAWGROUP.COM
Co-counsel for Plaintiff
/s/ Ralph W. Confreda, Jr.
Ralph W. Confreda, Jr., Esq.
1244082.1
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Filing # 82090990 E-Filed 12/13/2018 03:41:47 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA U.S. BANK, N.A., SUCCESSOR TRUSTEE CASE NO.: CACE18002037 TO LASALLE BANK, NATIONAL ASSOCIATION, ON BEHALF OF THE HOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I TRUST 2006- HE10, ASSET-BACKED CERTIFICATES SERIES 2006-HE10, Plaintiff, NORA DUNCAN AKA NORA JEAN DUNCAN, ET AL., Defendants. / MOTION TO WITHDRAW AS CO-COUNSEL FOR PLAINTIFF COMES NOW, McGlinchey Stafford (“McGlinchey”), in accordance with Florida Rule of Judicial Administration 2.505, and hereby moves this Honorable Court to allow said law firm to withdraw as co-counsel for the Plaintiff in the above-captioned matter and in support thereof, states as follows: 1. McGlinchey filed a Notice of Appearance as Co-Counsel for the Plaintiff in this case on or about May 5, 2018 for the purpose of handling a specific phase of the instant litigation. 2. The specific issue has now been successfully resolved. McGlinchey now seeks to withdraw as co-counsel for the Plaintiff in this matter and be relieved of all duties and responsibilities related to said representation in this action. 3. The law firm of Tromberg Law Group, 1515 South Federal Highway, Suite 100, Boca Raton, FL 33432, eservice@tromberglawgroup.net with whom McGlinchey was co-counsel in this case, shall remain and serve as counsel for the Plaintiff. 1244082.1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/13/2018 3:41:47 PM.****WHEREFORE, McGlinchey hereby requests that this Honorable Court allow McGlinchey to withdraw as co-counsel for the Plaintiff in this matter, relieve McGlinchey from all further obligations and responsibilities in this matter, and any such other relief this Court deems just and proper. Dated: December 13, 2018 1244082.1 Respectfully submitted, McGLINCHEY STAFFORD /s/ Ralph W. Confreda, Esq. Ralph W. Confreda, Jr., Esq. Florida Bar No. 85794 1 E. Broward Blvd, Suite 1400 Fort Lauderdale, FL 33301 Telephone: (954) 356-2513 Fax: (954) 333-3847 Primary E-Mail: rconfreda@meglinchey.com Secondary E-Mail: August jruiz@meglinchey.com CO-COUNSEL FOR PLAINTIFFCERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, via e-portal and/or U.S. mail as indicated below on this 13th day of December, 2018 to the following: FAEQUA A. KHAN, ESQ. 14707 S. DIXIE HWY, STE. 101 MIAMI, FL 33176 DJONES@DLIONESLAW.COM FKHAN@DLJONESLAW.COM Counsel for Nora Duncan and Robert Duncan MARIE FOX, ESQ. TROMBERG LAW GROUP, P.A. 1515 SOUTH FEDERAL HIGHWAY, SUITE 100 BOCA RATON, FL 33432 ESERVICE@TROMBERGLAWGROUP.COM Co-counsel for Plaintiff /s/ Ralph W. Confreda, Jr. Ralph W. Confreda, Jr., Esq. 1244082.1