Case 2:19-cv-01105-JCC Document 12 Filed 08/29/19 Page 1 of 4

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Honorable John C. Coughenour
Hearing Date: 9/6/2019
Without Oral Argument

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UNITED STATES DISTRICT COURT
WESTERN DISTRCIT OF WASHINGTON
AT SEATTLE

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DISCOVERY PARK COMMUNITY
ALLIANCE, a Washington non-profit
corporation; and ELIZABETH A. CAMPBELL,

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Petitioners/Plaintiffs,

No. 2:19-cv-01105-JCC
MOTION TO WITHDRAW AS
COUNSEL FOR
PETITIONERS/PLAINTIFFS
WITHOUT SUBSTITUTION

v.
CITY OF SEATTLE,

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Respondent/Defendant.

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COMES NOW Daniel J. Frohlich and Thomas Dickson of Dickson Frohlich, PS and
hereby moves this Court for an Order allowing counsel for the Petitioners/Plaintiffs,
DISCOVERY PARK COMMUNITY ALLIANCE, a Washington non-profit corporation; and
ELIZABETH A. CAMPBELL, to withdraw (collectively “Petitioners”).
Daniel J. Frohlich and Thomas Dickson of Dickson Frohlich currently are listed as
counsel for Petitioners and hereby request withdrawal and in support thereof state:
Petitioners have terminated the services of Dickson Frohlich, PS and have so informed
this Court in Docket #10 and #11. This office is unaware of any substituting counsel for the
Petitioners.

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MOTION TO WITHDRAW AS COUNSEL
USDC 2:19-cv-01105-JCC
Page 1 of 4

DICKSON   FROHLICH
1200 EAST D STREET
TACOMA, WASHINGTON 98421
(253) 572-1000 - FACSIMILE (253) 572-1300

 Case 2:19-cv-01105-JCC Document 12 Filed 08/29/19 Page 2 of 4

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Petitioner Discovery Park Community Alliance, a Washington non-profit corporation,
has been advised of the following pursuant to LCR 83.2(b)(4):

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(4) A business entity, except a sole proprietorship, must be
represented by counsel. If the attorney for a business entity, except a
sole proprietorship, is seeking to withdraw, the attorney shall certify
to the court that he or she has advised the business entity that it is
required by law to be represented by an attorney admitted to practice
before this court and that failure to obtain a replacement attorney by
the date the withdrawal is effective may result in the dismissal of the
business entity’s claims for failure to prosecute and/or entry of default
against the business entity as to any claims of other parties.

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Counsel for Petitioners requests to withdraw and there will be no material adverse

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impact on the interests of the Petitioners.
The Plaintiffs’ last known address is as follows:
Discovery Park Community Alliance
4027 21st Avenue West, #206
Seattle, WA 98199
Phone: (206) 283-9127

Elizabeth A. Campbell, Pro Se
4027 21st Avenue West, #206
Seattle, WA 98199
Phone: (206) 283-9127

Attached to this Motion is a Certificate of Service certifying that this Motion for
Order to Withdraw was served on the clients (Plaintiffs) and opposing counsel. Accordingly,
Daniel Frohlich and Thomas Dickson of Dickson Frohlich, PS, respectfully requests that this
Motion be granted.
This Motion is brought in accordance with LCR 83.2(b)(1).
DATED this 29th day of August 2019.

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MOTION TO WITHDRAW AS COUNSEL
USDC 2:19-cv-01105-JCC
Page 2 of 4

DICKSON   FROHLICH
1200 EAST D STREET
TACOMA, WASHINGTON 98421
(253) 572-1000 - FACSIMILE (253) 572-1300

 Case 2:19-cv-01105-JCC Document 12 Filed 08/29/19 Page 3 of 4

DICKSON FROHLICH, P.S.

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DANIEL J. FROHLICH, WSBA No. 31437
THOMAS L. DICKSON, WSBA No. 11802
Withdrawing Attorneys for
Petitioners/Plaintiffs

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MOTION TO WITHDRAW AS COUNSEL
USDC 2:19-cv-01105-JCC
Page 3 of 4

DICKSON   FROHLICH
1200 EAST D STREET
TACOMA, WASHINGTON 98421
(253) 572-1000 - FACSIMILE (253) 572-1300

 Case 2:19-cv-01105-JCC Document 12 Filed 08/29/19 Page 4 of 4

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CERTIFICATE OF SERVICE

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Under penalty of perjury under the laws of the State of Washington, I declare that on
the date below, I cause to be delivered a copy of the foregoing Pleading to the following by
the method described below:

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PARTY/COUNSEL

DELIVERY INSTRUCTIONS

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Roger Wynne
Patrick Downs
Assistant City Attorney
Land Use Section Director
Seattle City Attorney’s Office
701 Fifth Avenue, Suite 2050
Seattle, WA 98104-7095
Phone: 206-233-2177
FAX: 206-684-8284
roger.wynne@seattle.gov
Lead Attorney for Defendants
Discovery Park Community Alliance
4027 21st Avenue West, #206
Seattle, WA 98199
Phone: (206) 283-9127
Elizabeth A. Campbell, Pro Se
4027 21st Avenue West, #206
Seattle, WA 98199
Phone: (206) 283-9127

 U.S. MAIL
 LEGAL MESSENGER
 EMAIL
 EXPRESS DELIVERY
 FACSIMILE
✓CM/ECF

Email and US First Class Mail
Prepaid & Certified Return
Requested
70180360000018689041
Email and US First Class Mail
Prepaid & Certified Return
Requested
70180360000018689058

Postage
Receipt

Postage
Receipt

DATED August 29th 2019, signed at Tacoma, Washington.

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_______________________________
Kimberly J. Lampman, WSBA No. 9100472

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MOTION TO WITHDRAW AS COUNSEL
USDC 2:19-cv-01105-JCC
Page 4 of 4

DICKSON   FROHLICH
1200 EAST D STREET
TACOMA, WASHINGTON 98421
(253) 572-1000 - FACSIMILE (253) 572-1300