GONEL v. ESSEX COUNTY COLLEGE

CourtDistrict Court, D. New Jersey
DecidedJuly 28, 2025
Docket2:25-cv-00950
StatusUnknown

This text of GONEL v. ESSEX COUNTY COLLEGE (GONEL v. ESSEX COUNTY COLLEGE) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GONEL v. ESSEX COUNTY COLLEGE, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

ALANDRE GONEL,

Plaintiff, Civil Action No. 25-950 (SDW) (JSA) v.

OPINION & ORDER ESSEX COUNTY COLLEGE,

Defendant.

ALLEN, U.S.M.J. Presently before the Court is the motion of Stewart Lee Karlin Law Group, P.C. (“Movant” or “law firm”), seeking to withdraw as counsel for Plaintiff Alandre Gonel. (ECF No. 13). Plaintiff filed a response, requesting additional time to retain new counsel while not apparently opposing the motion to withdraw. (ECF No. 15). The official docket confirms that Defendant Essex County College did not submit any opposition. No oral argument was heard pursuant to Federal Rule of Civil Procedure 78. Having considered all of the parties’ submissions, and for the reasons set forth below, and for good cause shown, the motion to withdraw is GRANTED. I. BACKGROUND On February 3, 2025, Plaintiff initiated this action, alleging Defendant unlawfully expelled Plaintiff from Essex County College’s nursing program based on his race and national origin, in violation of Title VI of the Civil Rights Act, 42 U.S.C. § 2000(d) et seq. and Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 et seq. (See generally ECF No. 1). The Complaint also includes a common law count for slander. (Id. ¶¶ 93–101). On April 17, 2025, Defendant filed a motion to dismiss the Complaint. (ECF No. 5). After the motion to dismiss was fully briefed, the Court received a letter from Plaintiff dated June 11, 2025, wherein he appears to take issue with Movant’s representation of him in this matter.1 In response to the June 11th letter, the Court scheduled a Telephonic Case Management

Conference for July 2, 2025. (ECF No. 12). On the day before the scheduled conference, Movant filed the instant motion, stemming from a purported breakdown in communication between the law firm and Plaintiff. According to Movant, the relationship is beyond repair, and thus seeks to withdraw from the case. During the July 2nd Conference, Plaintiff and defense counsel both indicated that they may oppose the motion. As memorialized in an order entered immediately following the Conference, any opposition had to be filed on or before July 21, 2025 and any reply had to be filed on or before July 28, 2025. (ECF No. 14). The Court also directed Movant to provide a copy of the July 2nd Order to Plaintiff. (Id.). No opposition was filed opposition by the court ordered deadline. Rather, on July 17, 2025, Plaintiff filed a letter, advising the Court that he has been actively seeking new legal counsel

without success and requesting until July 31, 2025 to notify the Court of the name of his new attorney or confirm that Plaintiff will be representing himself pro se. (ECF No. 15). II. THE INSTANT MOTION In support of the motion, Daniel E. Dugan, Esq., an attorney with the Movant law firm submitted a certification raising two key arguments. (See generally Counsel Cert., ECF No. 13- 1). First, a breakdown in communication has occurred between Movant and Plaintiff as demonstrated by Plaintiff’s June 11th letter to the Court. (Id. ¶ 5-12). Movant certifies that

1 Since the June 11th letter arguably reveals attorney-client privileged communications, out of an abundance of caution, the Court did not direct Plaintiff’s June 11th letter to be filed on the official court docket.

2 “[s]ignificant and irreconcilable differences have arisen between [Movant] and Plaintiff,” (id. ¶ 4), rendering their “relationship . . . beyond repair.” (Id. ¶ 12). Second, Plaintiff has “repeated[ly] engage[d] in inappropriate behaviors despite explicit instructions from counsel to the contrary.” (Id. ¶ 15). According to Movant, Plaintiff has directly contacted Defendant without defense

counsel present and repeatedly “arriv[ed] in-person at [counsel’s] offices without an appointment, refusing to leave the building[,] requiring removal from the building by security, and verbally abusing staff.” (Id. ¶¶ 16–17). Movant also submits that after Plaintiff provided a copy of his June 11th letter to Movant, the law firm informed Plaintiff of its intention to seek leave to withdraw, “based upon the contents of the letter and his continued behavior . . . .” (Id. ¶ 8). III. DISCUSSION Local Civil Rule 102.1 provides, in relevant part, “[u]nless other counsel is substituted, no attorney may withdraw an appearance except by leave of Court.” L. Civ. R. 102.1. Other courts in this District have recognized “‘[w]hether to permit an attorney to withdraw is within the discretion of a court.’” Mazariegos v. Monmouth Cty. Corr. Inst., Civ. No. 12-5626, 2017 U.S.

Dist. LEXIS 211786, at *5 (D.N.J. Dec. 27, 2017) (citation omitted); see also Cuadra v. Univision Communs., Inc., Civ. No. 09-4946, 2012 U.S. Dist. LEXIS 48431, at *14 (D.N.J. Apr. 4, 2012). Further, under Local Civil Rule 103.1, the New Jersey Rules of Professional Conduct (“RPC”) govern the conduct of attorneys before the District of New Jersey. L. Civ. R. 103.1(a); accord In re Congoleum Corp., 426 F.3d 675, 687 (3d Cir. 2005) (citing United States v. Balter, 91 F.3d 427, 435 (3d Cir. 1996)); Haines v. Liggett Grp., Inc., 814 F. Supp. 414, 423 (D.N.J. 1993). As such, in reviewing a motion to withdraw, courts in this District apply RPC 1.16, which governs an attorney’s withdrawal from client representation. Subsection (b) of RPC 1.16 addresses the grounds on which an attorney may be permitted to withdraw from representing a client as 3 follows: (1) withdrawal can be accomplished without material adverse effect on the interests of the client;

(2) the client persists in a course of action involving the lawyer’s services that the lawyer reasonably believes is criminal or fraudulent;

(3) the client has used the lawyer’s services to perpetrate a crime or fraud;

(4) the client insists upon taking action that the lawyer considers repugnant or with which the lawyer has a fundamental disagreement;

(5) the client fails substantially to fulfill an obligation to the lawyer regarding the lawyer’s services and has been given reasonable warning that the lawyer will withdraw unless the obligation is fulfilled;

(6) the representation will result in an unreasonable financial burden on the lawyer or has been rendered unreasonably difficult by the client; or

(7) other good cause shown for withdrawal exists.

RPC 1.16(b). Further, subsection (d) of RPC 1.16 provides, in relevant part, that “[u]pon termination of representation, a lawyer shall take steps to the extent reasonably practicable to protect a client’s interests, such as giving reasonable notice to the client, allowing time for reemployment of other counsel, surrendering papers and property to which the client is entitled . . . .” RPC 1.16(d). Guided by RPC 1.16(b), courts in this District consider four criteria in evaluating a motion to withdraw: (1) the reasons why withdrawal is sought,

(2) the prejudice withdrawal may cause to litigants,

4 (3) the harm withdrawal might cause to the administration of justice and

(4) the degree to which withdrawal will delay resolution of the case.

Haines, 814 F. Supp. at 423 (citation omitted); see also U.S. ex rel. Cherry Hill Convalescent, Ctr., Inc. v. Healthcare Rehab Sys., Inc., 994 F. Supp. 244, 252-53 (D.N.J. 1997). Here, in considering the foregoing factors, this Court finds that permitting Movant to withdraw as counsel for Plaintiff is warranted.

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