LEÓN COSGROVE, LLP 

255 ALHAMBRA CIR. I 8TH FLOOR I MIAMI, FL 33134 I T 305.740.1975 I WWW.LEONCOSGROVE.COM 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-21979-CV-ALTONAGA 

MIKE ELBERT NEAL, 

Plaintiff, 

v. 

UNIT OFFICER DELMAN LUMPKINS, UNIT 

OFFICER FRADE, CAPTAIN ANGELA F. 

LAWRENCE, and SERGEANT TERRANCE 

HAMILTON, 

Defendants. 

______________________________________________/ 

MOTION TO WITHDRAW AS COUNSEL 

OF RECORD FOR PLAINTIFF MIKE ELBERT NEAL 

Pursuant to Local Rule 11.1(d)(3)(A), John R. Byrne, of the law firm of León Cosgrove, 

LLP, Diego Perez Ara and the law firm of León Cosgrove, LLP respectfully request the entry of 

an Order permitting their withdrawal from the representation of Plaintiff Mike Elbert Neal in the 

above-referenced matter. In support, the undersigned states as follows: 

1. On May 12, 2020, Mr. Byrne from the law firm of León Cosgrove, LLP and the 

law firm of León Cosgrove, LLP appeared in this action by filing a complaint [ECF No. 1]. 

2. On September 16, 2020, Mr. Perez Ara filed a notice of attorney appearance [ECF 

No. 29]. 

3. As a result of irreconcilable differences, Mr. Byrne, Mr. Perez Ara and the law firm 

of León Cosgrove, LLP are moving to withdraw from their representation of Mr. Neal. 

4. Pursuant to Local Rule 11.1(d)(3)(A), undersigned has served Mr. Neal and 

opposing counsel with a notice of this motion by email. To undersigned’s knowledge, Mr. Neal 

Case 1:20-cv-21979-CMA Document 35 Entered on FLSD Docket 08/02/2021 Page 1 of 2
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LEÓN COSGROVE, LLP 

255 ALHAMBRA CIR. I 8TH FLOOR I MIAMI, FL 33134 I T 305.740.1975 I WWW.LEONCOSGROVE.COM 

does not have new or remaining counsel. Undersigned counsel is unaware of Mr. Neal’s current 

mailing address. 

5. This motion is not filed for the purposes of delay and undersigned counsel has taken 

all steps reasonably practicable to protect the client’s interests. 

WHEREFORE, John R. Byrne and Diego Perez Ara and the law firm of León Cosgrove, 

LLP respectfully request the entry of an Order permitting their withdrawal from the representation 

of Plaintiff Mike Elbert Neal in the above-referenced matter and to be relieved of any further 

responsibility of the handling of this matter. A proposed order is attached hereto and will also be 

submitted via e-mail to the Court as prescribed by Section 3I(6) of the CM/ECF Administrative 

Procedures. 

CERTIFICATE OF CONFERENCE IN COMPLIANCE WITH S.D. FLA. L.R. 7.1(A)(3) 

Pursuant to S.D. Fla. L.R. 7.1(a)(3), the undersigned counsel contacted counsel for 

Defendants regarding the relief requested in this motion. Counsel for Unit Officer Delman 

Lumpkins does not oppose. Counsel for the county, Defendants Captain Angela F. Lawrence and 

Sergeant Terrance Hamilton take no position. 

Dated: August 2, 2021 Respectfully submitted, 

s/John R. Byrne 

John R. Byrne 

 Florida Bar No. 126294 

Email: jbyrne@leoncosgrove.com 

Email: cmanzano@leoncosgrove.com 

Diego Pérez Ara 

 Florida Bar No. 1023765 

Email: dperez@leoncosgrove.com 

Email: jfelipe@leoncosgrove.com 

León Cosgrove, LLP 

255 Alhambra Circle, 8th Floor 

Coral Gables, Florida 33134 

Telephone: 305.740.1975 

Counsel for Plaintiff

Case 1:20-cv-21979-CMA Document 35 Entered on FLSD Docket 08/02/2021 Page 2 of 2