On April 05, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Harbor 29 Condominium Association, Inc.,
and
Aspen Specialty Insurance Company,
for Insurance Claim
in the District Court of Miami-Dade County.
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Filing # 73502392 E-Filed 06/13/2018 01:23:15 PM
1057
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
HARBOR 29 CONDOMINIUM ASSOC., INC., CASE NO.: 2017-008138-CA-01
Plaintiff,
VS.
ASPEN SPECIALTY INSURANCE COMPANY,
Defendant.
MOTION TO WITHDRAW AS COUNSEL
Litigation & Recovery law Center, P.L., ("LRLC"), by and through the undersigned
counsel, moves to withdraw as counsel of record for the Plaintiffs, HARBOR 29
CONDOMINIUM ASSOC., INC. The grounds for this motion are as follows:
1. Irreconcilable differences have arisen between LRLC and the Plaintiffs that make it
impossible for LRLC to continue to represent their interests in this matter.
2. LRLC, on behalf of the Plaintiffs, requests that the Court:
a. Grant Plaintiffs thirty (30) days to obtain new counsel; and
b. Stay these proceedings during the thirty (30) day period.
3. LRLC additionally requests that any and all documents be forwarded to the attention of
HARBOR 29 CONDOMINIUM ASSOC., INC., 710 NE 29th Street, Unit #4C, Miami, FL
United States 33137
4. LRLC certifies that this motion is not being filed for purposes of delay
WHEREFORE, Litigation & Recovery law Center, P.L. requests that this Court enter an
Order allowing it to withdraw as attorneys for the Plaintiffs and granting the extensions of the
deadlines described above
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18" Avenue « Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that a true and correct copy of the foregoing was provided by e-mail
to: William S. Berk, Esq. of Berk, Merchant & Sims, PLC (Wberk@berklawfirm.com;
Mjoseph@berklawfirm.com; Sgetman@berklawfirm.com; Msoler-rodriguez@berklawfirm.com)
this June 12, 2018.
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18th Avenue
Suite 321
North Miami Beach, Florida 33162
Phone: (305) 760-2314
Fax (305) 760-2498
Direct email: Richard@losslitigators.com
Pleading email: service@losslitigators.com
By: __/s/ Richard Litofsky
Richard Litofsky, Esquire
Fla. Bar No: 822965
Page 2 of 2
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)
Document Filed Date
June 13, 2018
Case Filing Date
April 05, 2017
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Filing # 73502392 E-Filed 06/13/2018 01:23:15 PM 1057 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA HARBOR 29 CONDOMINIUM ASSOC., INC., CASE NO.: 2017-008138-CA-01 Plaintiff, VS. ASPEN SPECIALTY INSURANCE COMPANY, Defendant. MOTION TO WITHDRAW AS COUNSEL Litigation & Recovery law Center, P.L., ("LRLC"), by and through the undersigned counsel, moves to withdraw as counsel of record for the Plaintiffs, HARBOR 29 CONDOMINIUM ASSOC., INC. The grounds for this motion are as follows: 1. Irreconcilable differences have arisen between LRLC and the Plaintiffs that make it impossible for LRLC to continue to represent their interests in this matter. 2. LRLC, on behalf of the Plaintiffs, requests that the Court: a. Grant Plaintiffs thirty (30) days to obtain new counsel; and b. Stay these proceedings during the thirty (30) day period. 3. LRLC additionally requests that any and all documents be forwarded to the attention of HARBOR 29 CONDOMINIUM ASSOC., INC., 710 NE 29th Street, Unit #4C, Miami, FL United States 33137 4. LRLC certifies that this motion is not being filed for purposes of delay WHEREFORE, Litigation & Recovery law Center, P.L. requests that this Court enter an Order allowing it to withdraw as attorneys for the Plaintiffs and granting the extensions of the deadlines described above LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18" Avenue « Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)CERTIFICATE OF SERVICE I HEREBY CERTIFY, that a true and correct copy of the foregoing was provided by e-mail to: William S. Berk, Esq. of Berk, Merchant & Sims, PLC (Wberk@berklawfirm.com; Mjoseph@berklawfirm.com; Sgetman@berklawfirm.com; Msoler-rodriguez@berklawfirm.com) this June 12, 2018. LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18th Avenue Suite 321 North Miami Beach, Florida 33162 Phone: (305) 760-2314 Fax (305) 760-2498 Direct email: Richard@losslitigators.com Pleading email: service@losslitigators.com By: __/s/ Richard Litofsky Richard Litofsky, Esquire Fla. Bar No: 822965 Page 2 of 2 LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)