Case Information
*1 Email: eturner@gtg.legal
Las Vegas, Nevada 89119
Tel: (725) 777-3000
Fax: (725) 777-3112
Attorneys for Defendant, Jody Marie Cuomo
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
GREGORY KELLY, an individual; Case No. 2:18-CV-00923-JAD-MDC Plaintiff, MOTION TO WITHDRAW AS v. COUNSEL OF RECORD JODY MARIE CUOMO, an individual;
Defendant.
Pursuant to Local Rule LR IA 11-6(b), the law firm of GARMAN TURNER GORDON LLP (“GTG”), counsel for Defendant, Jody Marie Cuomo (“Ms. Cuomo”), hereby re-submits its Motion to Withdraw as Counsel for Ms. Cuomo (“Motion”). This Motion is made and based upon the following Memorandum of Points and Authorities, the Declaration of Erika Pike Turner, Esq., attached hereto as Exhibit A , the papers and pleadings in this case, and any oral argument that may be heard by this Court.
MEMORANDUM OF POINTS AND AUTHORITIES There are four (4) factors the court will consider when ruling on the Motion: 1) the reasons why withdrawal is sought;
2) the prejudice withdrawal may cause to other litigants;
3) the harm withdrawal might cause to the administration of justice; and 4) the degree to which withdrawal will delay the resolution of the case.
Castillo v. W. Range Ass’n , No. 3:16-cv-00237-RCJ-CLB, 2024 U.S. Dist. LEXIS 60553, at *5 (D.Nev. Mar. 29, 2024).
As demonstrated by the attached declaration of counsel, good cause exists for this court to *2 grant GTG leave to withdraw as counsel for Ms. Cuomo.
1) The reasons why withdrawal is sought: Withdrawal is sought because Plaintiff Gregory
Kelly (“Mr. Kelly”) has so multiplied the proceedings in recent years, Ms. Cuomo can no longer afford to pay for GTG’s services.
2) The prejudice withdrawal may cause to Mr. Kelly, the harm withdrawal may cause to
the administration of justice and the degree to which withdrawal will delay the resolution of the case: There are no pending hearings or trial. Pursuant to the court’s order [ECF No. 145] compelling the production of certain additional information from Ms. Cuomo, on June 9, 2025, a supplemental production was made to Mr. Kelly. A notice of compliance with the court’s order was filed on June 9, 2025 [ECF No. 146]. There are consequently no outstanding discovery requests or disputes.
Based on the foregoing, withdrawal under the circumstances is justified, and, pursuant to LR IA 11-6(b), GTG respectfully requests that this Court grant its Motion to Withdraw as Counsel for Ms. Cuomo.
Dated this 9 day of June, 2025.
/s/ Erika Pike Turner Las Vegas, NV 89119 Attorneys for Defendant, Jody Marie Cuomo IT IS SO ORDERED. The Motion is granted.
___________________________ Hon. Maximiliano D. Couvillier III United States Magistrate Judge Dated: 6-27-25
*3 CERTIFICATE OF SERVICE
The undersigned, an employee of Garman Turner Gordon LLP, hereby certifies that on the 9 day of June 2025, he caused a copy of the foregoing MOTION TO WITHDRAW AS COUNSEL OF RECORD , to be served electronically to all parties of interest through the Court's CM/ECF system as follows:
Gregory Kelly
3915 W. Davis St. Ste. 130, #135
Conroe, TX 77304
Email: gkcollects@gmail.com Plaintiff In Proper Person
A copy is also being sent via U.S. mail, certified mail and email to Ms. Cuomo’s last known address and email address:
Jody Cuomo
201 Rosemary Lane
Las Vegas, NV 89107
Email: Jodicuomo07@yahoo.com
/s/ Max Erwin An employee of GARMAN TURNER GORDON LLP