DOCKET NO. KNL-CV19-5020805-S : SUPERIOR COURT SUNBELT RENTALS INC. : J.D. OF NEW LONDON v. : AT NEW LONDON THE M&M GROUP, LLC, ET AL. : OCTOBER 15,2021 MOTION TO WITHDRAW APPEARANCE Pursuant to Practice Book section 3-10, undersigned counsel hereby moves this Court to withdraw his firm’s appearance on behalf of the defendants, THE M&M GROUP, LLC and MICHAEL GRILLO, in the above-referenced matter. In support of this motion, undersigned counsel hereby represents and asserts as follows: 1) This case was initiated by an Application for Prejudgment Remedy, as well as a ‘Summons and Complaint, filed on or about September 25, 2019; 2) It is alleged that the defendants owe Sunbelt Rentals a balance of $26,456.20 for the rental and non-payment of two backhoe units from the plaintiff for use by the defendant, The M&M Group, LLC; 3) The plaintiff claims that the defendants, Michael Grillo and Bryan Balezun, entered into a personal guaranty of debts of The M&M Group, LLC; 4) Undersigned counsel appeared in this action on behalf of the defendants, The M&M_ Group, LLC and Michael Grillo, on November 5, 2020, and has provided them with competent legal representation and legal services since that time; 5) Despite being provided with competent legal services and legal representation, Mr. Grillo has not fully reimbursed undersigned counsel for his firm’s services;power wore LLC ser Herron, CT 6108 6) Undersigned counsel has requested payment from Mr. Grillo numerous times, both verbally and in writing. Despite repeated promises that he will make payment, Mr. Grillo has made no payment; 7) Undersigned counsel also reached a settlement agreement in this matter with plaintiff's counsel pursuant to settlement authority granted by Michael Grillo on behalf of himself and The M&M Group, LLC. 8) Despite waiting several months for Mr. Grillo to sign the settlement papers and make the settlement payment, he has neglected to do so. Instead, he keeps making appointments to come into our office to do so and then does not show up. 9) The relationship between the defendants, Michael Grillo and The M&M Group, LLC, and undersigned counsel has irretrievably broken down; 10) Undersigned counsel is willing to further address the specifics of relationship directly with the Court during the hearing on this matter, when it the Court; 11) Reasonable notice of this motion has been given to all other attomeys and parties of record, as well as to the defendants, Michael Grillo and The M&M Group, LLC, by way of a copy of this motion; 12) Michael Grillo‘s last known address is 20 Jordon Drive, Norwich, CT 06360; 13) Undersigned counsel has attached hereto as Exhibit A, a copy of the Notice sent to ‘Mr. Grillo which complies with the notice requirements of Practice Book section 3-10(b); 14) Undersigned counse! has also attached hereto Exhibit B, a draft Order regarding a remote virtual hearing and the requirements as to Service of the order upon the party that counsel seeks to withdraw representation from.WHEREFORE, undersigned counsel hereby moves this court to grant this Motion to Withdraw as Counsel for the defendants, Michael Grillo and The M&M Group, LLC. THE DEFENDANTS, THE M&M GROUP, LLC and MICHAEL GRILLO By:_/s/303597, Lawrence H. Adler, Esq. ADLER LAW GROUP, LLC 111 Founders Plaza, Suite 1102 East Hartford, CT 06108 Telephone: (860) 282-8686 Juris No. 428826 CERTIFICATION This is to certify that a copy of the foregoing was sent via facsimile, email and/or regular mail on this 15th day of October, 2021, to the following counsel of record and non- appearing parties: Jared Alfin, Esq Hassett & George PC 945 Hopmeadow Street Simsbury, CT 06070 Non-appearing party: Bryan Balezun 38 Birch Heights Road Franklin, CT 06254 ‘it Fonoene muse sume s02 Ast Huetrono, CT 08108some s102 and via certified mail to: Michael Grillo 20 Jordan Drive Norwich, CT 06360 /s/303597, Lawrence H. Adler, Es Commissioner of the Superior CourtEXHIBIT AADLER Law Group, LLC ATTORNEYS: 414 Founpers PLaza - Sure 1102 East HARTFORD, CONNECTICUT 06108 ‘TELEPHONE (860) 282-8686 + Fax (860) 282-8688 Lawrence H. ADLER \LADLER@ADLERLAWGROUPLLC.COM October 15, 2021 Michael Grillo The M&M Group, LLC 20 Jordan Drive Norwich, CT 06360 NOTICE OF MOTION RE: Sunbelt Rentals, Ine. v. The M&M Group, LLC, et al. J.D. of New London at New London Docket No. KNL-~CV19-5020805-S Dear Mr. Grillo: As you know, undersigned counsel, Adler Law Group, LLC, represents you and The M & M Group, LLC in the above-referenced legal matter Sunbelt Rentals, Ine. v. The M & M Group, LLC, et al, Docket No. KNL CV 19-5020805 S and has provided you with legal services in furtherance thereof. Unfortunately, you have not paid for the iegal services provided, which you authorized and approved. In addition, you have failed to show up for scheduled meetings and you do not return telephone calls. Based on the forgoing, I have no choice but to file the attached Motion to Withdraw Appearance as counsel for you in this matter. Please see the enclosed Motion to Withdraw Appearance which has been filed with the New London Superior Court in the matter Sunbelt Rentals, Inc. v. The M & M Group, LLC, et al, Docket No. KNL CV 19-5020805 S. Please be advised of the following: 1) In the Motion to Withdraw Appearance, Adler Law Group, LLC is seeking the Court’s permission to no longer represent Michael Grillo and The M&M Group, LLC in this case, 2) If you wish to be heard on our Motion to Withdraw as Counsel, the hearing will be scheduled on: ; 2021, at Connecticut Superior Court at New London, 70 Huntington St., New London, CT 06320. The Motion to Withdraw Appearance will be set down by the Court for argument on a date3) and time in the near future. As soon as we receive a date and time from the Court, we will be certain to advise you. 4) You are entitled to be heard and may appear in Court on the date of the hearing and address the Court concerning the motion. The motion will be heard at the Superior Court for the Judicial District of New London at New London, located at 70 Huntington Street, New London, CT; 5) If the Motion to Withdraw is granted, you should either obtain another attorney or file an appearance on your own behalf with the court; 6) If you do neither of the options spelled out in 4) above, you will not receive notice of court proceedings in the case and a default may be rendered against you. Ifyou have any questions regarding the above, please feel free to reach out to me. Sincerely, Lawrence H. Adler, Esq. Enel.EXHIBIT Bpros NO.: KNL-CV19-5020805-S : SUPERIOR COURT UNBELT RENTALS, INC. : 4D. OF NORWICH \v. : AT NEW LONDON [THE M&M GROUP, LLC, ET AL ORDER REGARDING: “— MOTION FOR PERMISSION TO WITHDRAW APPEARANCE ‘The foregoing, having been considered by the Court, is hereby: ORDER: A remote virtual hearing, on the record, regarding the motion to withdraw appearance has been scheduled on SO at” DO NOT COME TO COURT ON THIS DATE. Service of this order shall be made at least 12 days betore the date of the virtual hearing on the party that counsel secks to withdraw representation from, All appearing counse! and self-represented parties may participate. Parties are ordered to confer and DEFENDANT'S COUNSEL is ORDERED to send ONE e-mail containing the names, Phone numbers and current e-mail addresses for ALL participating parties to the Caseflow Office NewLondon.Caseflow@jud.ct.gov copied to all counsel, at least TWO court days before the date of the hearing. Instructions tor connecting to the hearing will be emailed to you before 5:00 p.m. the da before the hearing. Please make sure that your email references the docket number of the case. > ‘The court may enter sanctions if counsel or an unexcused party fails to participate in the hearing. By Order of the Court. Hon. Al questions regarding the hearing should be directed to the civil caseflow office at NewLondon.Caseflow@ju.ct.gov Judge: Processed by:. ‘This document may be signed or verified clectronically and has the same validity and status as a document with physical (pea-o-pupe) signature, For more information, see Section LE ofthe State of Connecticut Supesin Coss tester Procedures and Technical Standards (htips:/ud.ct goviexternal/super/B-Services/e-standards pdf), section 51-193¢ of the Connecticut General Statutes and Connecticut Practice Book Section 4-4. KNL-CV19-5020805-S Page 1 of 1