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 # 74788136 E-Filed 07/11/2018 03:21:16 PM
1016
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
EDWARDO ROJAS A/A/O HARBOR 29 CASE NO.: 2017-010921-CA-01
CONDOMINIUM ASSOC., INC., consolidated w/ 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 Plaintiff, EDWARDO ROJAS A/A/O
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. Plaintiff has been made aware that LRLC intends to withdraw from the case and is in the
process of securing new counsel
LRLC, on behalf of the Plaintiff, requests that this Court:
we
a. Grant Plaintiff thirty (30) days to obtain new counsel; and
b. Stay these proceedings during the thirty (30) day period.
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 Plaintiff 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 July 11, 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
July 11, 2018
Case Filing Date
April 05, 2017
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Filing # 74788136 E-Filed 07/11/2018 03:21:16 PM 1016 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA EDWARDO ROJAS A/A/O HARBOR 29 CASE NO.: 2017-010921-CA-01 CONDOMINIUM ASSOC., INC., consolidated w/ 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 Plaintiff, EDWARDO ROJAS A/A/O 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. Plaintiff has been made aware that LRLC intends to withdraw from the case and is in the process of securing new counsel LRLC, on behalf of the Plaintiff, requests that this Court: we a. Grant Plaintiff thirty (30) days to obtain new counsel; and b. Stay these proceedings during the thirty (30) day period. 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 Plaintiff 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 July 11, 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)