McGhee v. Chavez

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 Joseph McGhee, No. CV-23-08041-PCT-DWL 10 Plaintiff, ORDER 11 v. 12 Fernando Chavez, et al., 13 Defendants. 14 15 Pending before the Court is the motion to withdraw as counsel of record without 16 client consent (Doc. 6) filed by Plaintiff’s “Limited Scope Representative,” Elizabeth 17 Sawyer (“Counsel”).1 18 Ninth Circuit law suggests a “justifiable cause” standard applies when, as here, the 19 client doesn’t affirmatively consent to the withdrawal request. Lovvorn v. Johnston, 118 20 1 Before this case was…