Motion To Withdraw As Counsel

Legal Counseling 3A

MEMBERS:
Aseron, Xavier Alexen || Eriguel, Eufranio Jr. || Limjoco,
Ernesto Angelo || Ortega, Danielle Bianca

MOTION TO WITHDRAW AS COUNSEL

COMES NOW, the undersigned counsel, unto the Honorable Court,

most respectfully states:
1.That the undersigned counsel has already terminated his attorneyclient relationship with the Plaintiff, Crumbs Corporation, particularly
because of the latter's pursuance of an unjust or immoral conduct of
the case;
2. That in view of the foregoing reasons, the undersigned counsel
could no longer adequately fulfill his obligations as legal counsel for
the said Plaintiff;
3. That Rule 22.01- A lawyer may withdraw his services in any of the
following cases: a) When the client pursues an illegal or immoral
course of conduct in connection with the matter he is handling;
4. That there is a need to protect the members of the legal profession
from clients who take advantages of their professional services. In
fact, the Honorable Supreme Court had the occasion to state that:
"Counsel, any counsel, if worthy of his hire, is entitled to be fully
recompensed for his services. With his capital consisting solely of his
brains and with his skill, acquired at tremendous cost not only in
money but in the expenditure of time and energy, he is entitled to the
protection of any judicial tribunal against any attempt on the part of
the client to escape payment of his fees. It is indeed ironic if after
putting forth the best that is in him to secure justice for the party he
represents, he himself would not get his due. Such an eventuality this
Court is determined to avoid. It views with disapproval any and every
effort of those benefited by counsel's services to deprive him of his
hard-earned
honorarium.
Such
an
attitude
deserves
condemnation."(Albano vs. Coloma, 21 SCRA 411).
5. As such, undersigned most respectfully requests that he be
allowed by this Honorable Court to withdraw his appearance in this
case as Counsel for the Plaintiff, Crumbs Corporation, without the
latter's express conformity.
PRAYER
WHEREFORE, premises considered, undersigned counsel most
respectfully prays that he be allowed to withdraw his appearance in
this case as counsel for the Plaintiff, Crumbs Corporation, dispensing
with the latter's express conformity, and that he be relieved of all his
responsibilities relative to this case.
Other reliefs just and equitable under the premises are likewise
prayed for.
Muntinlupa City, Philippines, on the 8th of October, 2015.

ALOE LAW FIRM

NOTICE OF HEARING
Counsel for the Plaintiff
Counsel's Address of Record: 10th Floor, Powerhouse Tower, Venture
St, Muntinlupa City, Philippine
Greetings: Please take notice that the foregoing Motion for
Withdrawal As Counsel shall be submitted for the consideration and
approval of the Honorable Court on Thursday, on the 8 th of October
2015, at 3:00pm or as soon as counsel and matter may be heard.

COPY FURNISHED:
OPPOSING COUNSEL