Filing # 193480518 E-Filed 03/06/2024 06:10:08 PM

IN IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

HECTOR JOSEPH DAGER GASPARD,

Plaintiff, Case No.: 2022-0022572-CA-01

vs.

INVERSIONES ALFA V, C.A.,

Defendant.

MOTION TO WITHDRAW AS COUNSEL FOR

DEFENDANT INVERSIONES ALFA V, C.A.

Eric M. Sodhi, Esq., Nathaniel M. Edenfield, Esq., Joshua L. Spoont, Esq., Michael

Ricobaldi, Esq., and the law firm Sodhi Spoont PLLC (“Counsel”), pursuant to Fla. R. Jud. Admin.

2.505(f)(1), hereby move to withdraw as counsel for Defendant, INVERSIONES ALFA V, C.A.

(“Defendant”), and state in support:

1. Counsel was retained to represent Defendant in this matter.

2. Irreconcilable differences have arisen between Defendant and Counsel such that

continued representation of Defendant is not possible or permissible.

3. The case is currently set on the 3-week trial docket commencing on April 22, 2024.

4. Pursuant to Fla. R. Jud. Admin. 2.505(f)(1), the following contact information is

provided for Defendant:

c/o Jose Gaspard

Corregimiento de San Francisco, Punta Pacifica, Isaac Hanono Street,

5. Counsel has provided notice to Defendant of this motion by e-mail listed above as

stated in the certificate of service. Counsel will further provide a copy of the notice of hearing

1
associated with this motion to Defendant in the same manner.

WHEREFORE, Eric M. Sodhi, Esq., Nathaniel M. Edenfield, Esq., Joshua L. Spoont, Esq.,

Michael Ricobaldi, Esq., and the law firm Sodhi Spoont PLLC, pursuant to Fla. R. Jud. Admin.

2.505(f)(1), respectfully request the Court enter an order granting this motion to withdraw as

counsel, excusing Eric M. Sodhi, Esq., Nathaniel M. Edenfield, Esq., Joshua L. Spoont, Esq.,

Michael Ricobaldi, Esq., and Sodhi Spoont PLLC from any further responsibility in this matter,

providing Defendant thirty (30) days to retain new counsel and staying this case during that time,

and granting such other relief the Court deems just and proper.

Dated: March 6, 2024 Respectfully submitted,

By: /s/ Eric M. Sodhi

Eric M. Sodhi
Florida Bar No. 583871
eric@sodhispoont.com
Secondary: service@sodhispoont.com
SODHI SPOONT PLLC
3050 Biscayne Blvd., Suite 701
Miami, Florida 33137
Tel: 305-907-7573

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 6, 2024, the foregoing was filed with the Clerk via
the Florida Courts E-filing Portal and that a true and correct copy was emailed therefrom to all
counsel of record. I further certify that a copy of this motion was sent to the Defendant by e-mail
as provided in paragraph 4, above.

By: /s/ Eric M. Sodhi

ERIC M. SODHI