Mark D. Rodriguez, Esq., an attorney duly admitted to practice law before the Courts of the State of New York, hereby affirms the following to be true under the penalties of perjury:
As such, I am fully familiar with the facts and circumstances of this matter as set forth herein based on my handling and review of this file.
From the outset, your Affirmant does not oppose Gorayeb & Associates, P.C.’s application to withdraw as counsel to plaintiff, however, it is respectfully requested that if the Court grants Gorayeb & Associates, P.C.’s application to be relieved, that a reasonable parameter be set for plaintiff to find new counsel, proceed pro se, or face automatic dismissal of this matter.
Allowing plaintiff a sixty (60) day time period to resume prosecution of this matter will result in undue prejudice to the Defendants and delays in discovery, which necessarily frustrate the judicial process.
For the foregoing reasons, your Affirmant respectfully requests that this Court limit plaintiff’s time frame to seek new counsel or proceed pro se to thirty (30) days to avoid further undue prejudice to the Defendant.