`
`IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
`
`IN AND FOR BROWARD COUNTY, FLORIDA
`
`CASE NO.: CACE—18-021740
`HORACIO PABLO MARTINEZ, individually,
`and MARIA MERCEDES MERINO, individually, DIVISION (04)
`
`Plaintiffs,
`
`V.
`
`IZABELLA BOGINSKY, individually and as the
`sole manager of A CLASS LIMOS, LLC,
`EDWARD BOGINSKY, a/k/a EDDIE BOGINSKY,
`Individually, and A CLASS LIMOS, LLC, a
`Florida Limited Liability Company,
`
`Defendants.
`
`A CLASS LIMOS, LLC, a
`
`Florida Limited Liability Company,
`
`Counterplaintiff/Third—Party Plaintiff,
`
`v.
`
`MARIA MERCEDES MERINO, individually, and
`WALL STREET TRANSPORTATION &
`
`LIMOUSINE LIMITED COMPANY, a
`
`Florida Limited Liability Company,
`
`Counterdefendant/Third-Party Defendant.
`
`
`/
`
`MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANTS IZABELLA
`
`BOGINSKY, EDWARD BOGINSKY AND DEFENDANT/COUNTER-
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`PLAINTIFF/THIRD-PARTY PLAINTIFF A CLASS LIMOS, LLC
`
`Peter T. Mavrick, Esq., Steven M. Canter, Esq., Mangit Gill, Esq. and Mavrick Law Firm
`
`move to withdraw as counsel of record for Defendants Izabella Boginsky, Edward Boginsky and
`
`Defendant/Counter—Plaintiff/Third-Party Plaintiff A Class Limos, LLC (hereinafter “Defendants”)
`
`due to irreconcilable differences. The undersigned counsel requests that Defendants be allowed 15
`
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/27/2018 2:58:51 PM.****
`
`
`
`days to hire new counsel and that all case deadlines applicable to Defendants be stayed for 15 days
`
`after the entry of the Court’s order on this Motion.
`
`The addresses of Defendants are as follows:
`
`lzabella Boginsky, 1903 NW 18th Street, Pompano Beach, FL 33069
`
`Edward Boginsky, 1903 NW 18th Street, Pompano Beach, FL 33069
`
`A Class Limos, LLC, 1903 NW 18th Street, Pompano Beach, FL 33069
`
`WHEREFORE, the undersigned respectfully requests that this Court enter an order
`
`granting the Motion to Withdraw as Counsel, relieving the undersigned of all further responsibility
`
`in the representation of Defendants in this matter, allowing Defendants 15 days to hire new
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`counsel, and that all case deadlines applicable to Defendants be stayed until they have new
`
`attorneys who appear in this case.
`
`
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true copy of the foregoing was served via the Florida Court
`System’s e—filing portal on November 27, 2018 to: Keith T. Grumer, Esq., Katz Barron, 100 NE.
`Third Avenue, #280, Fort Lauderdale, FL 33301:
`(primary e-mail: kt r éikatzbari*tin.c01n
`
`
`
`secondary e—mail: sml Etikatzbarroncom and miaefile ééfiiikatzbarroneom) and by US Mail to Wall
`
`
`Street Transportation & Limousine Limited Company, c/o Registered Agent Dade County
`Corporate Agents, Inc, 20801 Biscayne Blvd, Suite 505, Aventura, Florida 33180. A true copy
`of the foregoing was also served via US Mail and Email to Defendants Izabella Boginsky, Edward
`Boginsky, and A Class Limos, LLC at 1903 NW 18th Street, Pompano Beach, FL 33069.
`
`Respectfully submitted,
`
`Mavrick Law Firm
`
`Attorneys for Defendants
`A CLASS LIMOS, LLC, Izabella Boginsky
`and Edward Boginsky
`1620 West Oakland Park Boulevard, Suite 300
`
`Fort Lauderdale, Florida 33311
`Telephone: (954) 564-2246
`Peter T. Mavrick, Esq.
`E-mail:
`_ eter iiimavricklawcom
`
`
`
`Steven M. Canter, Esq.
`E-mail: stcvcn grimavrick
`
`lawcom
`
`
`
`
`
`BY: /s/ Steven M. Canter
`
`Peter T. Mavrick
`
`Florida Bar No.: 0083739
`
`Steven M. Canter
`
`Florida Bar No.: 605891
`
`
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