NO. 3:17-CV-01557-BR; George v. House of Hope Recovery, et al.; 

Counsel for Plaintiff’s Motion to Withdraw as Counsel for Plaintiff – 

Page 1 of 4

The Good Law Clinic, PLLC

WSBA#36036 / OSB#012636

211 E. 11th Street, Suite 105

Vancouver, WA 98660

Phone: (360) 694-4530

Facsimile: (360) 694-4659

E-mail: moloy@goodlawclinic.com

HONORABLE STACIE BECKERMAN

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

PORTLAND DIVISION

CONSTANCE GEORGE

Plaintiff,

v.

HOUSE OF HOPE RECOVERY, et al.

Defendants.

NO. 3:15-CV-01277-SB 

COUNSEL FOR THE 

PLAINTIFF’S UNOPPOSED 

MOTION TO WITHDRAW AS 

COUNSEL FOR PLAINTIFF

I. CERTIFICATE PURSUANT TO LR 7.1

This Motion is made by Plaintiff’s counsel, Moloy K. Good, (hereinafter “Plaintiff’s 

counsel”). Plaintiff’s counsel has conferred with counsel for each separate Defendant regarding 

this motion, and none of the counsel for Defendants oppose this Motion. Plaintiff’s counsel has 

provided Plaintiff Constance George with a copy of this Motion. 

II. MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF 

Pursuant to LR 83-11, Plaintiff’s counsel respectfully moves this Court for an order 

allowing him to withdraw as counsel for the Plaintiff immediately. 

Plaintiff’s counsel seeks to withdraw for professional considerations. Trial in this case is 

set for March 13, 2018 which will allow Plaintiff Constance George adequate time to obtain new 

Case 3:15-cv-01277-SB Document 91 Filed 12/27/17 Page 1 of 4
NO. 3:17-CV-01557-BR; George v. House of Hope Recovery, et al.; 

Counsel for Plaintiff’s Motion to Withdraw as Counsel for Plaintiff – 

Page 2 of 4

The Good Law Clinic, PLLC

WSBA#36036 / OSB#012636

211 E. 11th Street, Suite 105

Vancouver, WA 98660

Phone: (360) 694-4530

Facsimile: (360) 694-4659

E-mail: moloy@goodlawclinic.com

counsel prior to the trial. Moreover, Plaintiff’s counsel will provide Plaintiff Constance 

George’s new counsel with a copy of his attorney file as soon as he receives a notice of 

representation, and consent from Plaintiff. 

If ordered, Plaintiff’s counsel is willing to submit additional information under seal or in 

chamber, outside the presence of Defendants or Defendants’ counsel. 

No party will suffer any prejudice if the withdrawal is granted. Plaintiff’s counsel is 

concerned that Plaintiff will suffer prejudice if the withdrawal is denied. 

DATED this 27TH day of December, 2017.

THE GOOD LAW CLINIC

/s/ Moloy K. Good

MOLOY K. GOOD OSB #012636

(360) 694-4530

Attorney for Plaintiff

Case 3:15-cv-01277-SB Document 91 Filed 12/27/17 Page 2 of 4
NO. 3:17-CV-01557-BR; George v. House of Hope Recovery, et al.; 

Counsel for Plaintiff’s Motion to Withdraw as Counsel for Plaintiff – 

Page 3 of 4

The Good Law Clinic, PLLC

WSBA#36036 / OSB#012636

211 E. 11th Street, Suite 105

Vancouver, WA 98660

Phone: (360) 694-4530

Facsimile: (360) 694-4659

E-mail: moloy@goodlawclinic.com

I hereby certify that on the 27th day of December, 2017, I served the foregoing Counsel 

for Plaintiff’s Motion to Withdraw as Counsel for Plaintiff, and the Declaration of Moloy Good 

in Support of Counsel for Plaintiff’s Motion to Withdraw as Counsel for Plaintiff on the 

following parties at the following addresses:

CERTIFICATE OF SERVICE

Rebecca Cambreleng

CAMBRELENG LAW, LLC

806 SW Broadway, Suite 1200

Portland, OR 97205

Of Attorneys for Defendants House of Hope 

Recovery and Patricia Barcroft 

ECF

Hand Delivery

Facsimile

U.S. Mail

Overnight Courier

Email

Kyle T. Abraham

BARRAN LIEBMAN LLP

601 SW 2nd Avenue, Suite 2300

Portland, OR 97204

Of Attorneys for Defendant Bridges to Change

ECF

Hand Delivery

Facsimile

U.S. Mail

Overnight Courier

Email

Case 3:15-cv-01277-SB Document 91 Filed 12/27/17 Page 3 of 4
NO. 3:17-CV-01557-BR; George v. House of Hope Recovery, et al.; 

Counsel for Plaintiff’s Motion to Withdraw as Counsel for Plaintiff – 

Page 4 of 4

The Good Law Clinic, PLLC

WSBA#36036 / OSB#012636

211 E. 11th Street, Suite 105

Vancouver, WA 98660

Phone: (360) 694-4530

Facsimile: (360) 694-4659

E-mail: moloy@goodlawclinic.com

Sean K. Connor

Ryan J. McLellan

SMITH, FREED & EBERHARD P.C.

111 SW 5th Avenue, Suite 4300

Portland, OR 97204

Of Attorneys for Defendant Washington County 

Department of Housing Services

ECF

Hand Delivery

Facsimile

U.S. Mail

Overnight Courier

Email

Moloy K. Good, OSB #012636

s/ Moloy K. Good

of Attorney for Plaintiff 

Case 3:15-cv-01277-SB Document 91 Filed 12/27/17 Page 4 of 4