IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LOCAL UNION NO. 626, UNITED BROTHERHOOD CIVIL ACTION 02-CV-2761

OF CARPENTERS AND JOINERS OF AMERICA 

PENSION FUND, LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

WELFARE TRUST FUND, 

LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

APPRENTICESHIP FUND AND ITS SUBSIDIARY,

T/A CARPENTERS LOCAL 626 JOINT 

APPRENTICESHIP TRAINING CENTER, INC.

AND

UNITED BROTHERHOOD OF CARPENTERS AND

JOINERS OF AMERICA, AFL-CIO LOCAL 626 OF

DELAWARE, DELAWARE STATE REGIONAL

COUNCIL OF CARPENTERS, INTERNATIONAL

HEALTH & SAFETY TRAINING FUND/

MARKETING FUND, CARPENTERS LOCAL 626

POLITICAL ACTION COMM ITTEE AND JOSEPH DURHAM

PLAINTIFFS

vs.

MIDDLE STATES DRYWALL, INC.,

J.R. COLDIRON & SONS, INC., 

COLDIRON ENTERPRISES, INC., 

COLDIRON BUILDING, INC., 

ALN CONSTRUCTION,

JOHN D. COLDIRON,

JOHN R. COLDIRON,

BRENDA PETERSON AND

GREG PETERSON

DEFENDANTS

CRAWFORD, WILSON & RYAN, LLC AND MICHAEL T. IMMS, ESQUIRE’S

MOTION FOR LEAVE TO WITHDRAWAL AS COUNSEL FOR 

DEFENDANT COLDIRON BUILDING, INC.

Crawford, Wilson & Ryan, LLC and Michael T. Imms, Esquire respectfully move this

Honorable Court grant leave to withdraw as counsel for Defendant Coldiron Building, Inc. for

the reasons set forth in the accompanying Memorandum of Law.

Respectfully submitted,

CRAWFORD, WILSON & RYAN, LLC

BY: _______________________________

MICHAEL T. IMMS, ESQUIRE

ATTORNEY I.D. NO. 77510

220 WEST GAY STREET

WEST CHESTER, PA 19380

610-836-3000

Case 2:02-cv-02761-RBS Document 22 Filed 05/13/2005 Page 1 of 7
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LOCAL UNION NO. 626, UNITED BROTHERHOOD CIVIL ACTION 02-CV-2761

OF CARPENTERS AND JOINERS OF AMERICA 

PENSION FUND, LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

WELFARE TRUST FUND, 

LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

APPRENTICESHIP FUND AND ITS SUBSIDIARY,

T/A CARPENTERS LOCAL 626 JOINT 

APPRENTICESHIP TRAINING CENTER, INC.

AND

UNITED BROTHERHOOD OF CARPENTERS AND

JOINERS OF AMERICA, AFL-CIO LOCAL 626 OF

DELAWARE, DELAWARE STATE REGIONAL

COUNCIL OF CARPENTERS, INTERNATIONAL

HEALTH & SAFETY TRAINING FUND/

MARKETING FUND, CARPENTERS LOCAL 626

POLITICAL ACTION COMM ITTEE AND JOSEPH DURHAM

PLAINTIFFS

vs.

MIDDLE STATES DRYWALL, INC.,

J.R. COLDIRON & SONS, INC., 

COLDIRON ENTERPRISES, INC., 

COLDIRON BUILDING, INC., 

ALN CONSTRUCTION,

JOHN D. COLDIRON,

JOHN R. COLDIRON,

BRENDA PETERSON AND

GREG PETERSON

DEFENDANTS

ORDER

AND NOW, this day of , 2005, upon consideration of the

Motion of counsel and any response thereto, it is hereby ORDERED that Crawford, Wilson &

Ryan, LLC and Michael T. Imms, Esquire are permitted to withdraw as counsel for Defendant

Coldiron Building, Inc. Defendant should find substitute counsel or proceed pro se.

BY THE COURT:

____________________________________

J.

Case 2:02-cv-02761-RBS Document 22 Filed 05/13/2005 Page 2 of 7
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LOCAL UNION NO. 626, UNITED BROTHERHOOD CIVIL ACTION 02-CV-2761

OF CARPENTERS AND JOINERS OF AMERICA 

PENSION FUND, LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

WELFARE TRUST FUND, 

LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

APPRENTICESHIP FUND AND ITS SUBSIDIARY,

T/A CARPENTERS LOCAL 626 JOINT 

APPRENTICESHIP TRAINING CENTER, INC.

AND

UNITED BROTHERHOOD OF CARPENTERS AND

JOINERS OF AMERICA, AFL-CIO LOCAL 626 OF

DELAWARE, DELAWARE STATE REGIONAL

COUNCIL OF CARPENTERS, INTERNATIONAL

HEALTH & SAFETY TRAINING FUND/

MARKETING FUND, CARPENTERS LOCAL 626

POLITICAL ACTION COMM ITTEE AND JOSEPH DURHAM

PLAINTIFFS

vs.

MIDDLE STATES DRYWALL, INC.,

J.R. COLDIRON & SONS, INC., 

COLDIRON ENTERPRISES, INC., 

COLDIRON BUILDING, INC., 

ALN CONSTRUCTION,

JOHN D. COLDIRON,

JOHN R. COLDIRON,

BRENDA PETERSON AND

GREG PETERSON

DEFENDANTS

CRAWFORD, WILSON & RYAN, LLC AND MICHAEL T. IMMS, ESQUIRE’S

MEMORANDUM OF LAW IN SUPPORT OF THEIR

MOTION FOR LEAVE TO WITHDRAWAL AS COUNSEL FOR 

DEFENDANT COLDIRON BUILDING, INC.

Crawford, Wilson & Ryan, LLC is a professional LLC, organized under the laws of the

Commonwealth of Pennsylvania with an address of 220 West Gay Street, West Chester,

Pennsylvania. 

Michael T. Imms is an adult individual licensed to practice law in the Supreme Court of

the Commonwealth of Pennsylvania, Attorney I.D. No. 77510 together Crawford, Wilson &

Ryan, LLC and Michael T. Imms will be referred to as “Attorneys”). 

Defendant Coldiron Building, Inc. will be hereinafter be referred to as “Coldiron”. 

Case 2:02-cv-02761-RBS Document 22 Filed 05/13/2005 Page 3 of 7
2

Attorneys entered their appearance on behalf of Coldiron in this matter intending at that

time to represent them in the defense of Plaintiffs’ claims. Attorneys filed an Answer on

Coldiron’s behalf. Subsequently, Coldiron consulted another law firm who practiced bankruptcy. 

Following that consultation, Coldiron indicated to Attorneys that it would be pursuing a course

of bankruptcy and that Attorneys were to cease any activity on its behalf until further notice. 

Attorneys have never received any further instructions from Coldiron regarding the defense of its

claims in the above-captioned matter or whether or not it has successfully been discharged in

bankruptcy. Subsequently, any further attempts by the Attorneys to contact Coldiron have gone

unanswered. 

In March, 2005, Attorneys received a call from the Court requesting a status on the case. 

Attorneys attempted to contact Coldiron by telephone on two (2) occasions in 

March, 2005 and by way of a letter dated April 1, 2005. Coldiron did not return Attorneys’ calls,

nor respond to the letter of April 1, 2005. Attorneys again attempted to contact Coldiron by

telephone in April, but their messages went unreturned. Attorneys are due an outstanding

balance from Coldiron for the services which had been rendered which has gone unpaid. 

Attorneys understood that if Coldiron was successful in filing its Bankruptcy Petition, that this

debt would be discharged, however, Attorneys have never received any notice regarding the

status of a bankruptcy filing from Coldiron and cannot tell whether or not this debt has been

discharged. 

Because of the failure of Coldiron to communicate with the Attorneys and to pay or

indicate that the outstanding charge had been discharged, the attorney-client relationship between

Coldiron and Attorneys has been irrevocably severed. Attorneys are of the opinion that they can

no longer provide competent and zealous advocacy to Coldiron in this or any other matter. 

For these reasons, Attorneys request this Honorable Court to grant leave for them to

withdraw as counsel for Coldiron in this matter. 

Case 2:02-cv-02761-RBS Document 22 Filed 05/13/2005 Page 4 of 7
3

WHEREFORE, Crawford, Wilson & Ryan, LLC and Michael T. Imms, Esquire

respectfully move this Honorable Court to grant them leave to withdrawal as counsel for

Defendant Coldiron Building, Inc. and direct that Coldiron retain other counsel or proceed pro se. 

Respectfully submitted,

CRAWFORD, WILSON & RYAN, LLC

BY: _______________________________

MICHAEL T. IMMS, ESQUIRE

ATTORNEY I.D. NO. 77510

220 WEST GAY STREET

WEST CHESTER, PA 19380

610-836-3000

Case 2:02-cv-02761-RBS Document 22 Filed 05/13/2005 Page 5 of 7
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LOCAL UNION NO. 626, UNITED BROTHERHOOD CIVIL ACTION 02-CV-2761

OF CARPENTERS AND JOINERS OF AMERICA 

PENSION FUND, LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

WELFARE TRUST FUND, 

LOCAL UNION NO. 626, UNITED BROTHERHOOD

OF CARPENTERS AND JOINERS OF AMERICA

APPRENTICESHIP FUND AND ITS SUBSIDIARY,

T/A CARPENTERS LOCAL 626 JOINT 

APPRENTICESHIP TRAINING CENTER, INC.

AND

UNITED BROTHERHOOD OF CARPENTERS AND

JOINERS OF AMERICA, AFL-CIO LOCAL 626 OF

DELAWARE, DELAWARE STATE REGIONAL

COUNCIL OF CARPENTERS, INTERNATIONAL

HEALTH & SAFETY TRAINING FUND/

MARKETING FUND, CARPENTERS LOCAL 626

POLITICAL ACTION COMM ITTEE AND JOSEPH DURHAM

PLAINTIFFS

vs.

MIDDLE STATES DRYWALL, INC.,

J.R. COLDIRON & SONS, INC., 

COLDIRON ENTERPRISES, INC., 

COLDIRON BUILDING, INC., 

ALN CONSTRUCTION,

JOHN D. COLDIRON,

JOHN R. COLDIRON,

BRENDA PETERSON AND

GREG PETERSON

DEFENDANTS

CERTIFICATION OF SERVICE

This is to certify that a true and correct copy of Crawford, Wilson & Ryan, LLC and

Michael T. Imms, Esquire’s Motion to Withdrawal as Counsel for Defendant Coldiron Building,

Inc. and the Memorandum of Law in support thereof, was served on all counsel of record and

unrepresented parties by means of forwarding a true and correct copy of said documentation on

the day of May, 2005, via First Class, U.S. Mail, postage prepaid, to:

Coldiron Building, Inc. Middle States Drywall, Inc. J.R. Coldiron & Sons, Inc.

c/o John P. Coldiron 17 West Miner Street P.O. Box 460

136 Farm View Drive West Chester, PA 19381 Newport Gap Pike

Oxford, PA 19363 Avondale, PA 19311

Case 2:02-cv-02761-RBS Document 22 Filed 05/13/2005 Page 6 of 7
2

Coldiron Enterprises, Inc. ALN Construction John D. Coldiron

17 West Miner Street P.O. Box 7717 845 Waterway Road

P.O. Box 660 Wilmington, DE 19803 Oxford, PA 19363

West Chester, PA 19381

John R. Coldiron Brenda Peterson Greg Peterson

17 West Miner Street P.O. Box 7717 P.O. Box 7717

P.O. Box 660 Wilmington, DE 19803 Wilmington, DE 19803

West Chester, PA 19381

Marc L. Gelman, Esquire

Jennings Sigmond

510 Walnut Street

Suite 1600

Philadelphia, PA 19106

Counsel for Plaintiffs

CRAWFORD, WILSON & RYAN, LLC

BY: _______________________________

MICHAEL T. IMMS, ESQUIRE

ATTORNEY I.D. NO. 77510

220 WEST GAY STREET

WEST CHESTER, PA 19380

610-836-3000

Case 2:02-cv-02761-RBS Document 22 Filed 05/13/2005 Page 7 of 7