Professional Documents
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SAM SABOURY,
CITY OF LANSING,
CAROL WOOD, JODY
WASHINGTON, and ADAM HUSSAIN,
Defendants.
SULLIVAN, WARD, ASHER & PATTON, P.C.
NOW COMES Sullivan, Ward, Asher & Patton, P.C., and for its Motion to
Withdraw as Counsel for Plaintiff states as follows:
1. The Michigan Rules of Professional Conduct, Rule 1.16(b), provides
that counsel may withdraw from representing a client if the withdrawal can be
accomplished without material adverse effect on the interest of the client, or if,
among other things, the representation will resolve in an unreasonable financial
burden on the lawyer or has been rendered unreasonably difficult by the client or
for other good cause.
2. During the course of this matter, Plaintiff has been unable to pay
invoices as they have come due and is unable to finance necessary litigation
expenses such that cooperation between the client and counsel has become
unreasonably difficult causing a breakdown in the attorney-client relationship.
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to allow Plaintiff adequate time to obtain new counsel if he wishes and time to
complete expert reports and expert/fact witness discovery.
6. An attorney may request permission to withdraw when there is good
cause to withdraw. Lipton v. Boesky, 110 Mich. App. 589 (1981). (Failure to pay
legal fees is good cause); Ambrose v. Detroit Edison Company, 65 Mich. App.
484 (1975). (Clients failure to cooperate is good cause to permit withdrawal of
counsel.)
7. Concurrence has been sought and granted by the client.
8. Concurrence has been sought and granted by opposing counsel.
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SULLIVAN, WARD,
ASHER & PATTON, P.C.
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BRIEF IN SUPPORT OF
MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF
For its Brief in Support of Sullivan, Ward, Asher & Patton, P.C.s Motion
to Withdraw as Counsel for Plaintiff, Sam Saboury, Counsel relies upon the
Michigan Rules of Professional Conduct 1.16, the pleadings filed in this matter
and the facts as set forth in its motion.
Respectfully submitted,
SULLIVAN, WARD,
ASHER & PATTON, P.C.
SULLIVAN, WARD, ASHER & PATTON, P.C.
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SULLIVAN, WARD,
ASHER & PATTON, P.C.
CERTIFICATE OF SERVICE
On this 6th, day of April, 2017, Jacqueline Nicholson filed the foregoing
document with the Clerk of the Court via the Courts ECF system, which will
/s/Jacqueline Nicholson