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aTY OF RENO, Plaintiff
l@cQprv Coughlin. Defendant
IN THE MUNICIPAL COURT OF THE CITY OF RENO
COUNTY OF WASHOE, STATE OF NEVADA
vs.
Dept 1110. 1, '/
...
Name (First, Mlddl .... !.ilst)

PO Box 3961. Reno. Nv. 89505
City, State, Zip
MOTIQN
Comes now the undersigned and here make the following request:
MOTION TO BE RELIEVE!;! AS CQVNSEL
This Motion is based on the following:
HENRY SOTELO. ESQ., has ZACHARY COUOHUN since August 13, 2() 12, and has petformed
legal services in that regard. Circumstances have developed which have led to the breakdown of
communications between Attorney and the Client, a difference of opinion and deterioration of the
Attorney/Client relationship. Nevada Supreme Omrt, Rule 46 provides:
The attorney in an action or special proceeding may be changed at any time before .judgment
or final determination us follows:
1. Upon consent oCthe attorney, approved by the client.
2. thereof O!l .. or thc client.
After judgment or fina! determination, an attorney may withdraw lIS attorney ofrccord at any
time upon the attorney's filing a withdrawal, with or without the client's consent.
(emphasis added). HENRY SOTELO, ESQ., moves this Court to issue an Order allowing the withdrawal of
counsel. There has not yct been a final determination in this case, therefore, the Court's permission is
necessary. Nevada Rules of Professional Conduct 1.16(b)
(0) Except as stated in paragraph (c), a lawyer may withdraw fi'om representing a client if
(I) Withdrawal cnn be accomplished without material adverse effect on lb, interests of the
client;
(2) The client persists in a COIUlle of action involving the lawyer's serviccs that the lawyer
rea.wnably believes is criminal or fraudulent;
(3) The cliem bas used the lawyer's services to perpetrate a crime or fraud;
(4) A client insists upon taking action that the: Imvyer considers 1Y!pugmmt or with w!tich
tlte lawyer Itas fu "Jame1<tai difu.greement;
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(5) The client mils substantially to fulftll an obligation to the lawyer regarding the lawyer's
services and has been given rea!lonable warning that the lawyer will withdraw unless the
obligation is thlfilled;
(6) The representation will result in an unreasonable financial burden on the lawyer or has
been rendered unreasonably difficult by the client; or
(7) Other good cause for withdrawal exists.
(emphasis added)
HENRY SOTELO, ESQ., SI.at0s sufficient ["ea.'IOIl;; .""ist for permitting HENRY SOTELO, ESQ., to w;thdr"w
from representation at this time.
HENRY SOTELO, ESQ, asserts it would be impossible for him to provide and competent
representation for ZACHAR Y COUGHLIN as the client insists upon taking a course of action that the lawyer
considers repugnant and with which the lawyer has a fundamental disagreement, In addition. ZACHARY
COUGHLIN and HENRY SOTELO, ESQ. are unable to engage in the type of open communication thaI would
be helpful in providing a reasonable chance of proper representation by HENRY SOTELO, ESQ.
Furthermore. as the case in Reno Municipal Court now stands, ZACriAR Y COUGHLIN is being charged with
a minor vehicle traffic violation: Unsecured Load, RMC 6.14,.130, The more serious charges ofTrcspassing
and Disturbing the Peace have been dismissed by the City Al10mey at the last trial date on U23f2012. Thus,
since ZACHARY COUGHLIN is not facing any jail time for the minor traffic violation, a COURT
APPOINTED Legal Defender is not necessary.
Finally, ZACHARY COUGHLIN will not be adversely all'ecled by this withdraw, as his no new trial date has
been reset, pending a Competency Hearing in Reno Justice Court on October 15, 2012. This allows
ZACHARY COUGHLIN enough time to retain new legal counsel.
Accordingly, HENRY SOTELO, ESQ., requests an order from this Court permitting him to immediately
withdraw from legal representation of ZACHARY COUGHLIN, This Motion is not made for the purposes of
delay. Deputy City Attorney Brian Sooudi has been notified ofthis Motion and has NO OBJECTION to the
above request
, declare under penalty of perjury that the foregoing is true and correct.
.
J61
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ORDtR
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the motion be:
YGramed __ ,Denied __ Other
DATED THIS of. .oCa 2012
We. , .. 8''---.. --.-'.,
HOnOrabUlf3Y Dilworth. Judge. Depc One