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SUPERIOR COURT
`:
`
`NHH-CV-24-6023554-S
`J. D. of New Haven
`:
`
`
`
`
`
`
`:
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`Seramonte CT LLC
`HOUSING SESSION
` :
`
`at New Haven
`
`:
`vs.
`
`:
`
` Phillip Johnson & Alexus Baker-Rowland : September 30, 2024
`
`MOTION TO WITHDRAW APPEARANCE PER P.B. §3-10
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`
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`The undersigned hereby moves to withdraw the appearance of Westfall & Behrens for the Plaintiff,
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`Seramonte CT LLC. There has been a fundamental change in the means and practices by which the client
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`is and will be pursuing its summary process actions. After careful consideration and consultation with the
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`client, the attorney and client have agreed to terminate their relationship such that the law firm of Westfall
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`& Behrens must withdraw its appearance from the instant case. The client has secured the services of
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`alternate counsel. Said counsel already has been filing summary process actions on behalf of the client in
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`this and other courts such that the withdrawal of Westfall & Behrens will be accomplished without any
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`materially adverse effect on the client.
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`
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`The volume of cases formerly handled by Westfall & Behrens for this client allowed it to manage
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`the occasional complex and time-consuming case such as the instant one. Absent such volume, this case is
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`unduly financially burdensome to Westfall & Behrens. Moreover, the nature and substance of the defenses
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`to this case will involve important policy decisions that should be made in consultation with the client’s
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`attorney of choice.
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`
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`Notice will further be given to the client and a copy thereof to the Court pursuant to the attached
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`notice upon the Clerk’s scheduling of this motion.
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`This case has not been assigned for pretrial or trial.
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`WHEREFORE:
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`The Plaintiff hereby asks the Court to grant this Motion to Withdraw.
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`
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`
`
`Westfall & Behrens
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`
`
`
`
`
`
` By:
`
`D. Kirt Westfall
`
`Westfall & Behrens
`
`PO Box 579
`
`Northford, CT 06472
`
`Tele: 203-484-9630
`
`Juris #417810
`
`
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`1
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`

`

`CERTIFICATION
`
`
`The undersigned counsel hereby certified that the foregoing and its attached draft notice were
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`mailed, first class mail, postage prepaid, to the following addresses on this 30th day of September, 2024:
`
`Attorney Amy Deborah Marx
`Assistance Association
`205 Orange Street
`\New Haven, CT 06510
`
`Seramonte CT LLC
`50 Chestnut Ridge Rd.
`Suite 205
`Montvale, NJ 07645-1814
`
`Atty Benjamin K. Potok
`(Seramonte CT LLC’s agent for service)
`747 Farmington Ave., Suite 9
`New Britain, CT 06053
`
`
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`
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`By: _______________________
` D. Kirt Westfall
`
`
`
`
`
`2
`
`

`

`
`SUPERIOR COURT
`:
`
`NHH-CV-24-6023554-S
`J. D. of New Haven
`:
`
`
`
`
`
`
`:
`
`Seramonte CT LLC
`HOUSING SESSION
` :
`
`at New Haven
`
`:
`vs.
`
`:
`
` Phillip Johnson & Alexus Baker-Rowland :
`
`
`
`, 2024
`
`NOTICE TO SERAMONTE CT LLC
`
`
`
`
`
`
`
`(1) The Motion to Withdraw filed by Westfall & Behrens will be heard by the Superior Court at 121 Elm
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`Street, 3rd Floor, Courtroom D on ______________.
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`(2) Seramonte CT LLC may appear in court on that date and address the Court concerning the motion.
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`(3) If the motion to withdraw is granted, Seramonte CT LLC should either obtain another attorney.
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`(4) if Seramonte CT LLC does neither, it will not receive notice of court proceedings in the case and a
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`nonsuit or default judgment may be rendered against such party.
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`Westfall & Behrens
`
`
`
`
`
`
`
`
` By:
`
`D. Kirt Westfall
`
`Westfall & Behrens
`
`PO Box 579
`
`Northford, CT 06472
`
`Tele: 203-484-9630
`
`Juris #417810
`
`
`
`
`
`3
`
`

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