Filing # 193480321 E-Filed 03/06/2024 06:06:15 PM

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

GOLD MOON FOUNDATION, a Case No.: 2022-007996-CA-01

Private Interest Foundation, created and
existing under the laws of Panama;

Plaintiff,
v.

PLAYA BLANCA CORPORATION, a

Florida corporation; and HECTOR JOSEPH
DAGER GASPARD, a citizen of Venezuela,

Defendants.
____________________________________/

SODHI SPOONT PLLC’S MOTION TO WITHDRAW AS COUNSEL

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 Plaintiff, GOLD MOON FOUNDATION

(“Plaintiff”), and state in support:

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

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

continued representation of Plaintiff is not possible or permissible.

3. The case is not currently set for trial.

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

provided for Plaintiff:

c/o Jose Gaspard

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

1
 5. Counsel has provided notice to Plaintiff 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

associated with this motion to Plaintiff 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 Plaintiff 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 Plaintiff by e-mail as
provided in paragraph 4, above.

By: /s/ Eric M. Sodhi

ERIC M. SODHI