UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

GREGORY SCOTT ) 

 ) 

 Plaintiff, ) 

 ) 

v. ) Civil Action No. 

) 2:06cv00654-MEF-WC 

 ) 

NORMENT SECURITY GROUP, INC. ) 

 ) 

 Defendants. ) 

RESPONSE TO MOTION FOR ENFORCEMENT AND MOTION FOR LEAVE 

TO WITHDRAW AS COUNSEL

The undersigned counsel for plaintiff Gregory Scott files this response to 

Defendant’s Motion for Enforcement, etc. and also moves this Court for leave to 

withdraw as counsel of record for plaintiff. The undersigned shows as follows in support 

of this motion and response: 

 Defendant’s Notice to the Court and Motion for Enforcement correctly sets forth 

the facts with respect to this situation. Mr. Scott told the undersigned “to present a 

demand for $12,500” in settlement of the case. Based on that authorization the demand 

was presented to defendant and accepted. Scott was then informed by a voicemail 

message that the case had been settled. Within a day or so Scott had responded claiming 

that when he said to “present the offer” to defendant he did not mean that he would 

necessarily accept that amount. I told him that under the circumstances I would no longer 

represent him if he backed out of the offer after it had been accepted, because he had 

given authorization. Upon reflection, Scott decided that he wanted to seek new counsel 

and “pursue his claim”. 

Case 2:06-cv-00654-MEF-WC Document 23 Filed 07/03/2007 Page 1 of 3
 There is now an irrevocable and irreconcilable conflict and breakdown between 

the undersigned and Mr. Scott. I am forwarding Defendant’s Notice to the Court and this 

Response to Mr. Scott today. I respectfully request that the Court allow me to withdraw 

as counsel of record, and in fairness to Mr. Scott enter an Order giving him a reasonable 

period of time to attempt to locate other counsel or to otherwise response to defendant’s 

Notice and Motion to Enforce. I assert a lien on any settlement proceeds for the amount 

which would have been payable as attorney’s fees and expenses under the terms of the 

agreement with respect to this case and ask that those amounts be paid out of the 

settlement if it is enforced or out of any ultimate settlement or verdict should the case 

proceed in some other fashion. 

 Respectfully submitted, 

______________________________ 

s/Braxton Schell, Jr. 

OF COUNSEL: 

Braxton Schell, Jr., P.C. 

1330 21st Way South, Suite 210 

Birmingham, Alabama 35205 

Telephone: (205) 933-8512 

CERTIFICATE OF SERVICE

I hereby certify that on July 3, 2007, I electronically filed the foregoing with the 

Clerk of the Court using the CM/ECF system which will send notification of such filing 

to the following: 

Bruce J. Downey, III 

Capell & Howard 

P. O. Box 2069 

Montgomery, Alabama 36102-2069 

Case 2:06-cv-00654-MEF-WC Document 23 Filed 07/03/2007 Page 2 of 3
This is to certify that a copy of the above and foregoing has been served on the 

following, by placing a copy of same in the United States mail, postage prepaid, this the 

3rd day of July, 2007.

Gregory Scott 

2667 Davenport Road 

Greenville, Alabama 36037 

______________________________

 s/Braxton Schell, Jr. 

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