Filed: Mar. 20, 2018
Latest Update: Mar. 20, 2018
Summary: STIPULATION AND [PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANT SUMMIT RECEIVABLES WILLIAM B. SHUBB , District Judge . STIPULATION AND [PROPOSED] ORDER FOR WITHDRAWAL OF COUNSEL AND ENTRY OF CLERK DEFAULT AGAINST DEFENDANT SUMMIT RECEIVABLES COME NOW, DEFENDANT SUMMIT RECEIVABLES; by and through its counsel of record; and ANTHONY GUADAGNA, personally: DEFENDANT SUMMIT RECEIVABLES and ANTHONY GUADAGNA, personally, hereby agree and stipulate as follows
Summary: STIPULATION AND [PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANT SUMMIT RECEIVABLES WILLIAM B. SHUBB , District Judge . STIPULATION AND [PROPOSED] ORDER FOR WITHDRAWAL OF COUNSEL AND ENTRY OF CLERK DEFAULT AGAINST DEFENDANT SUMMIT RECEIVABLES COME NOW, DEFENDANT SUMMIT RECEIVABLES; by and through its counsel of record; and ANTHONY GUADAGNA, personally: DEFENDANT SUMMIT RECEIVABLES and ANTHONY GUADAGNA, personally, hereby agree and stipulate as follows:..
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STIPULATION AND [PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANT SUMMIT RECEIVABLES
WILLIAM B. SHUBB, District Judge.
STIPULATION AND [PROPOSED] ORDER FOR WITHDRAWAL OF COUNSEL AND ENTRY OF CLERK DEFAULT AGAINST DEFENDANT SUMMIT RECEIVABLES
COME NOW, DEFENDANT SUMMIT RECEIVABLES; by and through its counsel of record; and ANTHONY GUADAGNA, personally:
DEFENDANT SUMMIT RECEIVABLES and ANTHONY GUADAGNA, personally, hereby agree and stipulate as follows:
1. To entry of clerk default against Summit Receivables;
2. To permit VERNON A. NELSON, JR., ESQ. and MARGARET G. FOLEY, ESQ., counsel of record for Summit Receivables, to withdraw from their representation of Summit Receivables in this matter;
3. That the contents of this stipulation are expressly based on DEFENDANT SUMMIT RECEIVABLES and ANTHONY GUADAGNA's joint and mutual understanding that:
a. DEFENDANT SUMMIT RECEIVABLES cannot be represented in this matter without counsel;
b. In the event that ANTHONY GUADAGNA, personally, does not retain new counsel in this matter; and in the further event that PLAINTIFFS LAURA NORDYKE and BONNIE NORDYKE pursue default judgment in this matter; then DEFENDANT SUMMIT RECEIVABLES will not be represented by counsel in this matter when PLAINTIFFS LAURA NORDYKE and BONNIE NORDYKE prove up their default judgment amount;
c. In the event that DEFENDANT SUMMIT RECEIVABLES does not retain new counsel, then ANTHONY GUADAGNA, personally, will not be able to present testimony or argument to the Court in connection with the Court's determination of the amount of default judgment in this matter in favor of PLAINTIFFS LAURA NORDYKE and BONNIE NORDYKE, which may include damages, attorney fees, and costs.
IT IS SO STIPULATED.
ORDER
Based upon the foregoing Stipulation, as well as the understanding reached on the record in open court during the proceeding on May 19, 2018, the Motion of VERNON A. NELSON, JR., ESQ. and MARGARET G. FOLEY, ESQ., counsel of record for Summit Receivables, to withdraw from their representation of Summit Receivables in this matter is hereby GRANTED.
