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UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

OMM IMPORTS, INC. d/b/a ZERO GRAVITY,

Plaintiff,

v.

EL SALES CORP d/b/a PREDIRE PARIS, 

and SHAHAR BEN SHABAT,

Defendants.

Case No. 1:20-cv-22740

MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANTS

EL SALES CORP D/B/A PREDIRE PARIS AND SHAHAR BEN SHABAT

MARK F. WARZECHA, ESQUIRE and the law firm of WIDERMAN MALEK, PL, 

(“Movants”), as counsel for Defendants EL SALES CORP D/B/A PREDIRE PARIS and

SHAHAR BEN SHABAT (“Defendants”), hereby file this Motion to Withdraw as Counsel for 

said Defendants.

1. Due to the irreconcilable differences that have arisen between the Movants and 

Defendants, Movant respectfully requests to be withdrawn as counsel for Defendants.

2. Defendants advised via email dated August 8, 2020 that they were immediately 

terminating the “legal relationship” and the “attorney client contract”. 

3. Movants requested Defendants’ substitute counsel to forward a substitution of counsel 

form on August 10, 2020 and again on August 13, 2020. 

4. Movant has not received a response from Defendants since August 8, 2020.

Case 1:20-cv-22740-KMW Document 13 Entered on FLSD Docket 08/14/2020 Page 1 of 3
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5. Movants have advised Defendants via email of the August 17, 2020 deadline to file a 

Joint Conference Report and Joint Proposed Scheduling Order, to which, Movants have 

not received an answer.

6. All future pleadings, court documents, correspondence, and other papers related to this 

case should be delivered directly to the Defendants at their mailing address: 5111 W. 

Knox Street, Tampa, FL 33634 or to new counsel in the event that Defendants retain 

other counsel as attorney of record and such counsel files a Notice of Appearance or 

otherwise appears in this matter as attorney of record.

WHEREFORE, MARK F WARZECHA, ESQUIRE, and the law firm of WIDERMAN 

MALEK, PL, request this Court enter an order allowing said attorney and law firm to withdraw 

from any and all further representation of Defendants in this matter and terminating their 

professional responsibility in connection with this lawsuit, as well as any and all further relief this 

Court deems just and proper.

Dated: August 14, 2020

WIDERMAN MALEK, PL

/s/ Mark F. Warzecha

Mark F. Warzecha

Florida Bar No. 95779

1990 W. New Haven Ave., Ste 201

Melbourne, FL 32904

Telephone: 321-255-2332

MFW@USLegalTeam.com 

ATTORNEYS FOR DEFENDANTS

EL SALES CORP D/B/A PREDIRE PARIS

AND SHAHAR BEN SHABAT

Case 1:20-cv-22740-KMW Document 13 Entered on FLSD Docket 08/14/2020 Page 2 of 3
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 14, 2020, a copy of Motion to Withdraw as Counsel 

for Defendants EL Sales Corp d/b/a Predire Paris and Shahar Ben Shabat was served via electronic 

mail on Attorneys Brown and Goldman and via U.S. Mail to Defendants at the following:

Alexander D. Brown, Esq.

FL Bar No.: 752665

abrown@conceptlaw.com

Adam S. Goldman, Esq.

FL Bar No.: 86761

agoldman@conceptlaw.com

THE CONCEPT LAW GROUP, P.A.

6400 N. Andrews Ave., Ste 500

Telephone: 754-300-1500

Facsimile: 754-300-1501

Defendant EL Sales Corp d/b/a Predire Paris 

5111 W. Knox Street 

Tampa, FL 33634

Defendant Shahar Ben Shabat

5111 W. Knox Street 

Tampa, FL 33634

/s/ Mark F. Warzecha

Mark F. Warzecha

Case 1:20-cv-22740-KMW Document 13 Entered on FLSD Docket 08/14/2020 Page 3 of 3