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Employment Attorneys

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

NELSON FERNANDEZ

Plaintiff,

v.

THE WALKING COMPANY, a foreign forprofit corporation

Defendant.

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Case No. 9:20-cv-80469

SPIRE LAW’S MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR 

DEFENDANT, THE WALKING COMPANY

Heather M. Meglino, Esquire and Spire Law LLC (Collectively “Spire Law”) pursuant to 

Rule 7.1, Local Rules of the U.S. District Court, Southern District of Florida, hereby move the 

Court for an Order allowing them to withdraw as counsel of record for Defendant, The Walking 

Company (“Defendant”), and as grounds therefor state as follows: 

1. Defendant retained Spire Law to defend their interests in this matter. 

2. Defendant has requested that Spire Law withdraw from representation in this matter.

3. Defendant has no objection to this motion and Spire Law is in agreement to terminate 

representation. 

4. An answer has not been filed in this matter and is due to be filed today on June 22, 2020.

5. Spire Law requests that Defendant be given thirty (30) days to retain new counsel, file a 

response at that time if it chooses, and that all proceedings be stayed during that period of time. 

6. The undersigned certifies that the requested enlargement of time is not being sought for 

purposes of delay or for any other improper purpose. Further, the granting of this motion will not 

result in any prejudice to Plaintiff as this matter is still in its very early stages. 

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7. Spire Law is providing a copy of this motion to Defendant by email as follows:

Julie Saltoun

Assistant General Counsel

The Walking Company

25 W. Anapamu St.

Santa Barbara, CA 93101

Fax (805) 962-9460

JulieS@thewalkingcompany.com

WHEREFORE, Heather M. Meglino, Esq. and Spire Law, respectfully request that this 

Court enter an Order granting Spire Law’s Motion to Withdraw as Counsel of Record for 

Defendant, The Walking Company, that Spire Law be relieved of any further responsibilities and 

obligations in connection with this matter, that Defendant be permitted thirty (30) days to retain 

new Florida counsel and file a response to the Complaint, as set forth in the proposed Order 

attached hereto as Exhibit “A.” and for such additional relief as the Court deems just and proper. 

Dated: June 22, 2020

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LOCAL RULE 7.1(a)(3) CERTIFICATE

Counsel for Defendant has conferred with counsel for Plaintiff who has no objection to 

the relief requested.

DATED this 22nd day of June, 2020.

Respectfully submitted,

Spire Law, LLC

12249 Science Drive, Suite 155

Orlando, Florida 32826

By: /s/Heather M. Meglino

Heather M. Meglino, Esq.

Florida Bar No. 91857

heather@spirelawfirm.com

 brook@spirelawfirm.com

Attorney for Defendant | The Walking Company

CERTIFICATE OF SERVICE

I hereby Certify that on this 22nd day of June, 2020. the foregoing was electronically filed 

with the Court by using the Southern District of Florida’s CM/ECF portal, which will send a notice 

of electronic filing to: Pelayo M. Duran, Esq. at duranandassociates@gmail.com at 4640 N.W. 7th 

Street, Miami, FL 33126-2309 and Roderick Victor Hannah, Esq. at rhannah@rhannahlaw.com at 

8751 W. Broward Blvd., Suite 303, Plantation, FL 33324.

/s/ Heather M. Meglino

Heather M. Meglino, Esq.

Case 9:20-cv-80469-KAM Document 15 Entered on FLSD Docket 06/22/2020 Page 3 of 6
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EXHIBIT “A”

Case 9:20-cv-80469-KAM Document 15 Entered on FLSD Docket 06/22/2020 Page 4 of 6
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www.spirelawfirm.com

Employment Attorneys

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

NELSON FERNANDEZ

Plaintiff,

v.

THE WALKING COMPANY, a foreign forprofit corporation

Defendant.

)

)

)

)

)

)

)

)

)

)

)

Case No. 9:20-cv-80469

ORDER ON SPIRE LAW’S MOTION TO WITHDRAW AS COUNSEL OF RECORD 

FOR DEFENDANT, THE WALKING COMPANY

THIS MATTER came before the Court on Spire Law’s Motion to Withdraw As Counsel 

of Record for Defendant, The Walking Company (“Defendant”), and the Court having reviewed 

the Motion and being otherwise fully advised in the premises, it is hereby

ORDERED AND ADJUDGED that:

1. Spire Law’s Motion to Withdraw as Counsel of Record for Defendant is hereby 

GRANTED.

2. Heather M. Meglino, Esq. and Spire Law are hereby relieved of any further 

obligations in connection with this matter. 

3. All further pleadings and correspondence directed to Defendant shall be sent to 

Julie Saltoun, Julie Saltoun, Assistant General Counsel, The Walking Company, 25 W. Anapamu 

St. Santa Barbara, CA 93101, Fax (805) 962-9460, JulieS@thewalkingcompany.com.

4. Defendant be given a thirty (30) day extension of time to file a response to the 

Complaint in this matter. 

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5. Defendant must be represented by counsel admitted in Florida in all proceedings in 

this matter and is directed to retain such counsel within thirty (30) days of this Order. 

DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida 

on this _____ day of ______, 2020. 

________________________________

KENNETH A. MARRA

DISTRICT JUDGE

Copies furnished to counsel of record via CM/ECF portal. 

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