IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVANIA
`
`RYDER TRUCK RENTAL, INC. f/k/a
`
`RUAN LEASING COMPANY,
`
`CIVIL DIVISION
`
`Plaintiff,
`
`AR 04—007349
`
`V.
`
`TOTAL TRANSPORTATION
`
`CORPORATION; et al.,
`
`Defendants.
`
`PETITION FOR LEAVE OF
`
`COURT TO WITHDRAW
`
`APPEARANCE
`
`
`,'-"l{(€i'ri[N‘{CDUHzY
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`
`[MT
`
`AI‘
`
`Filed on Behalf of:
`
`Robert Goldman, Esquire
`Counsel for Total Transportation
`Corporation, et al.,
`Defendants.
`
`Counsel of Record for this Party:
`Robert A. Goldman, Esquire
`PA ID. No. 69679
`
`300 Mt. Lebanon Blvd.
`
`Suite 209—D
`
`Pittsburgh, PA 15234
`(412) 531-6879
`
`W75 Y/M/Qé,
`
`
`PENNSYLVANIA
`
`RYDER TRUCK RENTAL, INC. f/k/a
`
`RUAN LEASING COMPANY,
`
`CIVIL DIVISION
`
`Plaintiff,
`
`AR 04—007349
`
`V.
`
`TOTAL TRANSPORTATION
`
`CORPORATION; et al.,
`
`Defendants.
`
`PETITION FOR LEAVE OF
`
`COURT TO WITHDRAW
`
`APPEARANCE
`
`
`,'-"l{(€i'ri[N‘{CDUHzY
`0531;:l8PM2:\3 “is'3‘TH'
`
`[MT
`
`AI‘
`
`Filed on Behalf of:
`
`Robert Goldman, Esquire
`Counsel for Total Transportation
`Corporation, et al.,
`Defendants.
`
`Counsel of Record for this Party:
`Robert A. Goldman, Esquire
`PA ID. No. 69679
`
`300 Mt. Lebanon Blvd.
`
`Suite 209—D
`
`Pittsburgh, PA 15234
`(412) 531-6879
`
`W75 Y/M/Qé,
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVNIA
`
`CIVIL DIVISION
`
`AR 04-007349
`
`)
`
`) )
`
`)
`)
`
`) )
`
`)
`
`) )
`
`)
`
`RYDER TRUCK RENTAL, INC. f/k/a
`
`RUAN LEASING COMPANY,
`
`Plaintiff,
`
`v.
`
`TOTAL TRANSPORTATION
`CORPORATION, et a1.,
`
`Defendants.
`
`NOTICE OF PRESENTATION
`
`To:
`
`Alessandra Gruelle
`
`Timothy Gruelle
`D. T. Gruelle Company
`301 Moon Clinton Road
`
`Moon Township, PA 15108
`
`TAKE NOTICE that the within Petition for Leave of Court to Withdraw
`
`Appearance will be presented to the Honorable Eugene B. Strassburger, III in the Court
`
`of Common Pleas of Allegheny County, City County Building, 414 Grant Street,
`
`Pittsburgh, Pennsylvania, Room 819 on Monday, July 17, 2006 at 1:30 p.m. or as soon
`
`thereafier at the convenience of the Court.
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVNIA
`
`CIVIL DIVISION
`
`AR 04-007349
`
`)
`
`) )
`
`)
`)
`
`) )
`
`)
`
`) )
`
`)
`
`RYDER TRUCK RENTAL, INC. f/k/a
`RUAN LEASING COMPANY,
`
`Plaintiff,
`
`v.
`
`TOTAL TRANSPORTATION
`CORPORATION, et al.,
`
`Defendants.
`
`PETITION FOR LEAVE OF COURT
`
`TO WITHDRAW APPEARANCE
`
`
`
`AND NOW, comes the Petitioner, counsel for Defendants, Total Transportation
`
`Corporation, et al., in the above referenced matter and files this Petition For Leave of
`
`Court to Withdraw Appearance and in support avers as follows:
`
`1.
`
`On or about November 16, 2004, plaintiff initiated this action in the
`
`arbitration division of this Court. Defendants subsequently retained the Law Offices of
`
`Robert Goldman (Petitioners herein) to assist in the defense of this matter.
`
`2.
`
`On or about June 28, 2005, following the arbitration hearing, defendants
`
`filed a timely appeal to the Court of Common Pleas.
`
`3.
`
`4.
`
`A trial in this matter is tentatively scheduled for December 8, 2006.
`
`Petitioner has provided legal services in the past to defendants on this and
`
`other legal matters and has been paid for those services.
`
`
`
`5.
`
`Approximately one month ago, Petitioner submitted invoices to
`
`Defendants for legal work performed on the instant matter along with legal work
`
`performed on other pending issues.
`
`6.
`
`Despite repeated demands, defendants have refused to pay Petitioner’s
`
`outstanding balance and have unreasonably demanded that Petitioner grant credits,
`
`among other things, a credit in excess of $6,000.00 for work performed by another
`
`attorney from another law firm over whom Petitioner exercised no control and for work
`
`which was done approximately one year ago by said other attorney. Petitioner has
`
`advised defendants to seek redress of their dispute with the other attorney through the fee
`
`dispute panel at the Allegheny County Bar Association or by filing suit. Defendants
`
`refuse and insist that Petitioner grant them a credit on his bill for the full amount of their
`
`disputed claim with the other attorney.
`
`7.
`
`As a small law firm, Petitioner does not have the financial resources to
`
`maintain a law practice and continue litigating the defense of this matter, including trial,
`
`if defendants refuse to render full payment. Furthermore, defendants have refused to
`
`reimburse Petitioner for costs advanced on defendants’ behalf.
`
`WHEREFORE, Petitioner respectfully requests that this Honorable Court grant
`
`Petitioner’s request to withdraw as counsel for all named defendants.
`
`Respectfully submitted,
`
`
`
`Robert A. Goldman, Esquire
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the foregoing
`
`Petition for Leave to Withdraw Appearance was served, unless otherwise indicated, Via
`
`United States First Class mail, postage pre-paid, this 5th day of July, 2006 upon the
`
`following:
`
`(Via facsimile 215-557-6353)
`
`Joel Flink, Esquire
`Salaman/Flink Law Offices
`
`Land Title Building
`Suite 1124
`
`100 South Broad Street
`
`Philadelphia, PA 191 10
`
`Alessandra Gruelle
`
`1319 Magee Road
`Sewickley, PA 15143
`
`Tim Gruelle
`
`D.T. Gruelle Company
`301 Moon Clinton Road
`
`Moon Township, PA 15108
`
` 6/
`
`Robert
`
`oldman
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVNIA
`
`CIVIL DIVISION
`
`AR 04-007349
`
`)
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`) )
`
`)
`)
`
`) )
`
`)
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`) )
`
`)
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`RYDER TRUCK RENTAL, INC. f/k/a
`RUAN LEASING COMPANY,
`
`Plaintiff,
`
`v.
`
`TOTAL TRANSPORTATION
`CORPORATION, et a1.,
`
`Defendants.
`
`ORDER OF COURT
`
`AND NOW, this2Kay ofJuly2006, upon consideration ofthe foregoing
`
`Petition For Leave Of Court To Withdraw Appearance, said Petition is GRANTED.
`
`Petitioner, Robert Goldman, Esquire is GRANTED leave to withdraw as counsel of
`
`
`
`
`
`
`
`
`
` record in the above captioned matter. I ' fu a procee '
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`a
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`may 0 tam
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