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Case 3:18-cv-02287-GPC-MSB Document 47 Filed 12/27/18 PageID.

3210 Page 1 of 9

1 CORRIGAN & MORRIS, LLP


Brian T. Corrigan (Cal Bar No. 143188)
2 bcorrigan@cormorllp.com
Stanley C. Morris (Cal Bar No. 183620)
3 sC&M@cormorllp.com
12300 Wilshire Boulevard, Suite 210
4 Los Angeles, CA 90025
Telephone: (310) 394-2800
5 Facsimile: (310) 394-2825
6 Attorneys for Defendants
BLOCKVEST, LLC, and REGINALD
7 BUDDY RINGGOLD, III aka RASOOL
ABDUL RAHIM EL
8
9
UNITED STATES DISTRICT COURT
10
SOUTHERN DISTRICT OF CALIFORNIA
12300 Wilshire Boulevard, Suite 210

11
CORRIGAN & MORRIS LLP

SECURITIES AND EXCHANGE Case No.: 18-CV-2287-GPC (MSB)


12 COMMISSION,
Los Angeles, CA 90025

13 Plaintiff, NOTICE OF MOTION AND


14 vs. MOTION TO WITHDRAW AS
COUNSEL FOR DEFENDANTS
15 BLOCKVEST, LLC, and REGINALD
BUDDY RINGGOLD, III aka RASOOL
16 ABDUL RAHIM EL,
17 Defendants. Date: March 8, 2019
Time: 1:30
18
Place: Courtroom 2D (2nd Floor -
19 Schwartz), Suite 2190
20 221 West Broadway
San Diego, CA 92101
21
22 Judge: Hon. Gonzalo P. Curiel
23
Complaint Filed:
24
OCTOBER 3, 2018
25
26
27
28

1
Case 3:18-cv-02287-GPC-MSB Document 47 Filed 12/27/18 PageID.3211 Page 2 of 9

1 TO THE PARTIES AND THEIR ATTORNEYS OF RECORD:


2 PLEASE TAKE NOTICE, that on March 8, 2019, at 1:30 p.m., or as soon
3 thereafter as the matter may be heard, in Courtroom 2D of the United States District
4 Court, Southern District of California, located at 221 West Broadway
5 San Diego, CA 92101, Corrigan & Morris LLP (“C&M”) as counsel for the
6 Defendants Blockvest LLC and Reginald B. Ringgold, III (collectively,
7 “Defendants”) will and hereby does move to withdraw as attorneys of record.
8 This motion is made pursuant to Southern District Local Rules 83.3(f)(3) and
9 83.4 and California Rule of Professional Conduct 1.16(a)(2), 1.16(b), and 1.16(d).
10 C&M so moves on the grounds that a conflict of interest has arisen such that
12300 Wilshire Boulevard, Suite 210

11 continued representation would cause C&M to violate the California Rules of


CORRIGAN & MORRIS LLP

Professional Conduct. Specifically, under Local rule 83.4 and California Rules of
Los Angeles, CA 90025

12
13 Professional Conduct 1.16(a)(2) C&M is required to withdraw from the
14 representation.
15 This motion is made following written notice to Defendants on December 10,
16 2018, and all parties who have appeared in this action. Defendants have served the
17 Defendants with this notice and filed a proof of service herewith.
18 This motion is based upon all the pleadings, papers in this action, the
19 supporting Declaration of Stanley C. Morris, the Memorandum of Points and
20 Authorities, and upon such argument of counsel as may be made at the hearing on
21 this motion.
22 Respectfully submitted,
23
24 Dated: December 27, 2018 CORRIGAN & MORRIS LLP
25 By: /s/ Stanley C. Morris
Attorneys for Defendants,
26
REGINALD B. RINGGOLD, III
27 and BLOCKVEST LLC
28

2
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1 MEMORANDUM OF POINTS AND AUTHORITIES


2 The Local Rules of the United States District Court for the Southern District of
3 California state that an attorney may not withdraw as counsel except by leave of the
4 court. Southern District of Cal. L. R. 83.3(f)(3). L.R. 83.4 further requires counsel to
5 comply with the California Rules of Professional Conduct. As such, Corrigan &
6 Morris LLP and Stanley C. Morris (collectively “C&M”) seek an order permitting it
7 to withdraw as attorney of record for Defendants Reginald B. Ringgold, III and
8 Blockvest LLC (collectively “Defendants”).
9 California Professional Rule of Conduct Rule 1.16 (a)(2) requies counsel to
10 withdraw if the lawyer knows or reasonably should know that he representation will
12300 Wilshire Boulevard, Suite 210

11 result in a violation of the California Rules of Professional Conduct. C&M


CORRIGAN & MORRIS LLP

reasonably believe that continued representation of the Defendants would cause


Los Angeles, CA 90025

12
13 C&M to violate the Rules of Professional Conduct. See Morris Decl. ¶ 16. California
14 Professional Rule of Conduct Rule 1.16 (b) provides, among other things, that a
15 lawyer may withdraw from representing a client if the client’s conduct renders it
16 unreasonably difficult for the lawyer to carry out the representation effectively; or if
17 the client breaches a material term of an agreement with, or obligation, to the lawyer
18 relating to the representation, and the lawyer has given the client a reasonable
19 warning after the breach that the lawyer will withdraw unless the client fulfills the
20 agreement or performs the obligation. Further, 1.16(d) requires the lawyer to take
21 reasonable steps to prevent foreseeable prejudice to the client such as providing
22 sufficient notice to permit the client to retain new counsel.
23 C&M seeks leave of the Court to withdraw as Defendants have created a
24 conflict of interest when they breached the client engagement agreement by: (i)
25 failing to make payments when due C&M; and (ii) engaging in conduct, such as
26 instructing the undersigned to file documents with the Court that do not meet FRCP
27 Rule 11 standards, that renders it impossible to carry out representation consistent
28 with California Rules of Professional Conduct. C&M has given the client more than

3
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1 two-weeks’ notice to locate replacement counsel, but Defendants have not provided
2 C&M with replacement counsel. There will be no harm to the Plaintiff as the case
3 was filed a little more than two-months ago and no trial date or a scheduling order is
4 in place. Ct. Dkt. # 1.
5 I. Facts
6 Defendants engaged C&M, on October 16, 2018, by executing an engagement
7 agreement. Paragraph 11 of that engagement agreement states:
8 Termination. You should know that either of us has the right
9 to terminate our representation at any time by giving reasonable
advance written notice of such decision. You also agree that we
10 shall be under no obligation to undertake or continue services
on any matter (a) if we deem such services to be in conflict with
12300 Wilshire Boulevard, Suite 210

11
CORRIGAN & MORRIS LLP

the interest of another client or with legal ethics, (b) your


Los Angeles, CA 90025

12 conduct renders it unreasonably difficult for us to carry out our


13 employment effectively, or (c) if you fail to make any payment
to the firm when due.
14
C&M has grounds to terminate under paragraph 11, sections a, b and c of the
15
foregoing engagement agreement. See, Declaration of Stanley C. Morris (“Morris
16
Decl.”), at ¶ 3. The same paragraph 11 states: “You agree to take steps to effectuate
17
this termination, including the execution of any necessary documents to complete our
18
withdrawal or discharge.” Id. The Defendants have not so cooperated or stipulated in
19
our termination or withdrawal. Thus, Defendants have breached the conduct and
20
financial obligations of the agreement. Id.
21
Since October 16, 2018, C&M worked diligently under emergency
22
circumstances to represent Defendants in connection with Court ordered expedited
23
discovery, and the preparation of substantial court filed documents and argument
24
before this Court in furtherance a successful opposition to the SEC’s Application for
25
Preliminary Injunction and responding to the Court’s Order for Expedited Discovery.
26
Ct Dkt. 6; Morris Decl. ¶ 4. Under the expedited discovery ordered by the Court, the
27
undersigned counsel personally assisted the Defendants throughout the
28
representation, including (a) representing Defendants at two depositions; (b)
4
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1 responding to interrogatories; (c) responding to document requests; (d) preparing an


2 ex-parte request for evidentiary hearing; (e) assisting in the preparation of extensive
3 evidentiary objections; and (f) traveling to San Diego to argue the opposition to the
4 SEC’s Application for Preliminary Injunction. Id. Both partners at C&M, Stanley
5 Morris and Brian Corrigan, assisted in many of these endeavors and attended the
6 preliminary injunction. Id. and Ct. Dkt. # 37.
7 On November 27, 2018, the Court denied the SEC’s application for a
8 preliminary injunction. Morris Decl. ¶ 5 and Court Dkt. # 41.
9 C&M is proud of the work it has done for the Defendants in this case and for
10 the results obtained for them. C&M seeks to withdraw from the representation
12300 Wilshire Boulevard, Suite 210

11 regrettably, and only after Defendants have made abundantly clear that such
CORRIGAN & MORRIS LLP

12 withdrawal was an ethical and practical necessity. Morris Decl. ¶ 6.


Los Angeles, CA 90025

13 Out of an abundance of caution, C&M has refrained from providing the Court
14 with the details of the communications with the client that make it necessary for
15 C&M to terminate the engagement. However, between November 27, 2018 and the
16 date of this filing, there has been a complete breakdown in the attorney-client
17 relationship. Morris Decl. ¶ 7.
18 Defendants have levied serious accusations against the undersigned counsel
19 and C&M in writing and verbally, on top of failing and refusing to abide by the clear
20 payment and conduct obligations set forth in the engagement agreement. In addition,
21 Defendants have announced they are not obligated to comply with and do not intend
22 to comply with the payment obligations going forward. Morris Decl. ¶ 8.
23 Defendants have instructed counsel to file certain documents that such clients
24 prepared without the benefit of counsel, and that, upon review, fall far short of the
25 professional standards required by the Court of my firm. Morris Decl. ¶ 9. C&M
26 refused to sign and file these papers with the Court and could not certify them as
27 appropriate papers in compliance with their duties under FRCP Rule 11. Id. The
28

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1 Defendants even attempted to file such documents with this Court without C&M’s
2 permission or signature, but such papers were rejected by the Court Clerk. Id.
3 Defendants have exhausted their legal retainer and have failed to make
4 payments when due and announced their intention not to comply with their payment
5 obligations in the future. Morris Decl. ¶ 10.
6 On December 10, 2018, C&M partner, Stanley C. Morris, notified the
7 Defendants via email, in an exchange which verified Defendants’ receipt of such
8 email, that pursuant to California Rule of Professional Conduct 1.16, Defendants
9 must find substitute counsel within two-weeks, or C&M would seek formally to
10 withdraw as their counsel from this case. Morris Decl. ¶ 11.
12300 Wilshire Boulevard, Suite 210

11 On December 11, 2018, C&M reminded the Defendants via email to Mr.
CORRIGAN & MORRIS LLP

12 Ringgold of the upcoming deadline to substitute C&M out of the case with new
Los Angeles, CA 90025

13 counsel and urging him to immediately hire replacement counsel. Morris Decl. ¶ 12.
14 Mr. Ringgold replied to the email disputing C&M’s right to terminate the
15 engagement. Id. C&M replied to him advising that he would have two-weeks to
16 locate replacement counsel and, if not, C&M would bring a motion to withdraw. Id.
17 C&M continued to work on the case, including preparing an extensive Answer
18 to the Securities and Exchange Commission’s lengthy Complaint, because such
19 answer was due on or around December 20, 2018. Morris Decl. ¶ 13.
20 On December 14, 2018, C&M sent another email reminding Mr. Ringgold of
21 the need to find replacement counsel and enclosed an executed substitution form.
22 Morris Decl. ¶ 14.
23 At my clients’ direction, on December 17, 2018, notwithstanding the
24 breakdown in client relationship and my December 10, 2018 notice to Defendants,
25 C&M sought to protect Defendants’ interest and C&M filed an Answer and
26 Affirmative Defenses to the SEC’s twenty-seven page Complaint (163 paragraphs) on
27 December 17, 2018, a copy of which had been sent to the client on December 10,
28 2018. Morris Decl. ¶ 29. C&M also sent a copy of the filed Answer to Mr. Ringgold

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1 and reminded him that C&M would file a motion to withdraw if replacement counsel
2 had not substituted into the case before the stated deadline. Morris Decl. ¶¶ 11, 15.
3 The undersigned counsel believes in good faith that neither he nor his firm can
4 continue to represent Defendants while complying with California Rules of
5 Professional Responsibility. Morris Decl. ¶ 16.
6 It is still very early in the case and no scheduling order or trial date has been set by
7 this Court yet. I have served a copy of these papers on the Defendants as described in
8 the proof of service filed herewith. Morris Decl. ¶ 17 and Ct Dkt. # 1.
9 II. Legal Argument
10 The Local Rules of this Court and the Rules of Professional Conduct of the
12300 Wilshire Boulevard, Suite 210

11 State Bar of California govern this Motion. Specifically, Local Rule 83.3(f)(3) of the
CORRIGAN & MORRIS LLP

12 U.S. District Court for the Southern District of California provides that an attorney
Los Angeles, CA 90025

13 must obtain leave of court in order to withdraw as counsel and must make a written
14 application which gives notice to the client and all other parties who have appeared in
15 this action. Here, C&M provided all the parties and the Defendants with seventeen
16 days advance notice of its intention to withdraw. Morris Decl. ¶ 11. In addition, C&M
17 provided notice to the Defendants of the consequences of such withdraw, including
18 that a corporate entity cannot be pro se.
19 Further Local Rule 83.4 provides that the California standards of professional
20 conduct are adopted as the standards of professional conduct of the Court and that all
21 attorneys must be familiar and in compliance with all requirements thereof.
22 Accordingly, California Rule of Professional Conduct 1.16, which pertains to the
23 withdrawal of counsel, governs C&M’s instant motion to withdraw before this Court.
24 Here, C&M has complied with Rule 1.16(d) by providing the Defendants with
25 substantial notice and allowing sufficient time for employment of other counsel.
26 Morris Decl. ¶¶ 11-14.
27 Once the foregoing requirement has been met, Rule 1.16 compels and
28 authorizes an attorney to withdraw as counsel of record for a client on multiple

7
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1 grounds that apply in this case. Specifically, Rule 1.16(a)(2) compels a lawyer to
2 withdraw if the lawyer knows or reasonably should know that the representation will
3 result in violation of these rules of the State Bar Act. Here, C&M has a conflict of
4 interest as a result of the Defendants’ insistent that counsel file documents that
5 counsel do not believe are consistent with FRCP Rule 11. Such direction creates a
6 conflict of interest that compels C&M to withdraw as counsel under 1.16(a). C&M
7 has concluded in good faith that it cannot continue to represent Defendants in
8 compliance with the rules of professional conduct. Morris Decl. ¶ 16. Further, Rule
9 1.1.6(b)(4) provides that an attorney may withdraw as counsel for a client if that
10 client’s conduct makes it “unreasonably difficult for the member to carry out the
12300 Wilshire Boulevard, Suite 210

11 employment effectively.” In light of the fact that Defendants have maliciously


CORRIGAN & MORRIS LLP

12 attacked Stanley Morris and levied serious ethical allegations against him and
Los Angeles, CA 90025

13 attempted to file documents with the court without counsel’s authorization, it follows
14 that it would be unreasonably difficult for Counsel to continue to represent the
15 Defendants in this matter. Morris Decl. ¶¶ 7, 8, and 9.
16 Further Rule 1.16(b)(5) provides that an attorney may withdraw if a client
17 breaches an agreement or obligation to the member as to expenses and fees. The
18 Defendants are in breach of their agreement to make certain payments required under
19 the engagement agreement and have announced their refusal to do so in the future.
20 Morris Decl. at ¶ 8.
21 Finally, in ruling on a motion to withdraw, courts generally consider (1) the
22 reasons why withdrawal is sought; (2) the prejudice withdrawal may cause to other
23 litigants; (3) the harm withdrawal might cause to the administration of justice; and (4)
24 the degree to which withdrawal will delay the resolution of the case. Irwin v. Mascott,
25 No. 97-4737, 2004 U.S. Dist. LEXIS 2826t4 at 4 (N. D. Cal. Dec. 1, 2004);
26 Canandaigua Wine Co., Inc. v. Moldauer, 2009 U.S. Dist. LEXIS 4238 1, 3-4 (E. D.
27 Cal. January 13, 2009). “Courts have also held that the failure to pay attorneys’ fees
28 may be grounds for withdrawal.” Id. at 4.

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1 Considering these facts, C&M is simply not able to effectively represent the
2 Defendants. Morris Decl. ¶ 16. Further, C&M’s withdrawal will not cause prejudice
3 to other litigants, harm the administration of justice, or delay resolution of the case.
4 Indeed, the case was filed on October 3, 2018. Ct Dkt. #1. Moreover, no scheduling
5 order or trial date has been set. Morris Decl. ¶ 17.
6 To ensure compliance with California Rule of Professional Conduct Rule
7 1.16(d), C&M provided Defendants with ample opportunity to find replacement
8 counsel. Morris Decl. ¶ 11. On December 10, 2018, C&M advised the Defendants in
9 writing that they were not in compliance with a material term of their agreement with
10 C&M and the verbal accusations toward C&M, and directions to file cross claims and
12300 Wilshire Boulevard, Suite 210

11 other documents that C&M believed would violate Rule 11 created a conflict of
CORRIGAN & MORRIS LLP

12 interest that made C&M’s representation impossible and impermissible under


Los Angeles, CA 90025

13 California Rules of Conduct. Morris Decl. ¶ 8.


14 Since at least December 10, 2017, Defendants have refused to comply to make
15 payments due under the engagement and even if they did comply with the payment
16 terms, C&M would be unable to continue to represent Defendants based on the break
17 down in the relationship, instructions to files documents that would violate Rule 11,
18 and the serious accusations made against C&M regarding their professional actions
19 and Defendants’ conduct. Morris Decl. ¶¶ 8, 9, 10, and 12.
20 III. CONCLUSION
21 For the foregoing reasons, C&M respectfully requests that the Court allow it to
22 withdraw as counsel of record for the Defendants Reginald B. Ringgold and
23 Blockvest LLC. C&M served a copy of these papers on the Defendants as described
24 in the proof of service filed herewith.
25
Dated: December 27, 2018 Respectfully submitted,
26
27 CORRIGAN & MORRIS, LLP
28
By: /s/ Stanley C. Morris
9
Case 3:18-cv-02287-GPC-MSB Document 47-1 Filed 12/27/18 PageID.3219 Page 1 of 5

1 CORRIGAN & MORRIS, LLP


Brian T. Corrigan (Cal Bar No. 143188)
2 bcorrigan@cormorllp.com
Stanley C. Morris (Cal Bar No. 183620)
3 scm@cormorllp.com
12300 Wilshire Boulevard, Suite 210
4 Los Angeles, CA 90025
Telephone: (310) 394-2800
5 Facsimile: (310) 394-2825
6 Attorneys for Defendants
BLOCKVEST, LLC and REGINALD
7 BUDDY RINGGOLD, III aka RASOOL
ABDUL RAHIM EL
8
9 UNITED STATES DISTRICT COURT
10 SOUTHERN DISTRICT OF CALIFORNIA
12300 Wilshire Boulevard, Suite 210

11 SECURITIES AND EXCHANGE Case No.: 18-CV-2287-GPC (MSB)


CORRIGAN & MORRIS LLP

COMMISSION,
Los Angeles, CA 90025

12
Plaintiff, DECLARATION OF STANLEY C.
13
vs. MORRIS IN SUPPORT OF MOTION
14 TO WITHDRAW AS COUNSEL TO
BLOCKVEST, LLC, and REGINALD
15 BUDDY RINGGOLD, III aka RASOOL DEFENDANTS BLOCKVEST, LLC,
ABDUL RAHIM EL, AND REGINALD BUDDY
16
Defendants. RINGGOLD
17
18 Date: March 8, 2019
Time: 1:30 p.m.
19
Place: Courtroom 2D (2nd Floor -
20 Schwartz), Suite 2190
21 221 West Broadway
San Diego, CA 92101
22
23 Judge: Hon. Gonzalo P. Curiel
24
Complaint Filed:
25
OCTOBER 3, 2018
26
27
28

1
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1 I, Stanley C. Morris, declare as follows:


2 1. I am an attorney at law duly admitted to practice before the Courts of the
3 State of California and the United States District Court, Southern District of
4 California. I am a partner at the law firm of Corrigan & Morris LLP (C&M), counsel
5 of record for defendants Blockvest, LLC and Reginald Buddy Ringgold, III
6 (collectively “Defendants”), in this action.
7 2. The facts stated in this declaration are known to me personally, and I
8 would and could competently testify there if called as a witness. This declaration is
9 filed under Local Rules 83.3 (f)(3) and 83.4 of the U.S. District Court for the
10 Southern District of California, seeking an order from this Court granting my request
12300 Wilshire Boulevard, Suite 210

11 that C&M and its lawyers, Brian T. Corrigan and I, be relieved as counsel
CORRIGAN & MORRIS LLP

12 Defendants.
Los Angeles, CA 90025

13 3. Defendants engaged C&M on October 16, 2018, by executing an


14 engagement agreement. Paragraph 11 of that engagement agreement states:
15 Termination. You should know that either of us has the right
16 to terminate our representation at any time by giving reasonable
advance written notice of such decision. You also agree that we
17 shall be under no obligation to undertake or continue services
18 on any matter (a) if we deem such services to be in conflict with
the interest of another client or with legal ethics, (b) your
19 conduct renders it unreasonably difficult for us to carry out our
20 employment effectively, or (c) if you fail to make any payment
to the firm when due.
21
C&M has grounds to terminate under paragraph 11, sections a, b and c of the
22
foregoing engagement agreement, and consistent with California Rule of Professional
23
Conduct 1.16. The same paragraph 11 states: “You agree to take steps to effectuate
24
this termination, including the execution of any necessary documents to complete our
25
withdrawal or discharge.” The Defendants have not so cooperated or stipulated in our
26
termination or withdrawal. Thus, Defendants have breached the conduct and financial
27
obligations of the agreement.
28

2
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1 4. Since October 16, 2018, C&M worked diligently on an emergency basis


2 to represent Defendants in connection with Court ordered expedited discovery, and
3 the preparation of substantial court filed documents and argument before this Court in
4 furtherance a successful opposition to the SEC’s Application for Preliminary
5 Injunction. I personally assisted the Defendants throughout the representation,
6 including: (a) representing Defendants at two depositions; (b) responding to
7 interrogatories; (c) responding to document requests; (d) preparing an ex-parte
8 request for evidentiary hearing; (e) assisting in the preparation of extensive
9 evidentiary objections; and (f) traveling to San Diego to argue the opposition to the
10 SEC’s Application for Preliminary Injunction. My partner, Brian Corrigan, assisted in
12300 Wilshire Boulevard, Suite 210

11 many of these endeavors and attended the preliminary injunction with me.
CORRIGAN & MORRIS LLP

5. On November 27, 2018, the Court denied the SEC’s application for a
Los Angeles, CA 90025

12
13 preliminary injunction.
14 6. I am proud of the work we have done for the Defendants in this case and
15 for the results obtained for them. C&M seeks to withdraw from the representation
16 regrettably, and only after Defendants have made abundantly clear that such
17 withdrawal was an ethical and practical necessity.
18 7. Out of an abundance of caution, I will refrain from providing the Court
19 the details of the communications that I have had with our client that make it
20 necessary for C&M to terminate the engagement. However, I believe I can say,
21 without jeopardizing the attorney-client privilege, that between November 27, 2018,
22 and the date of this declaration, there has been a complete breakdown in the attorney-
23 client relationship.
24 8. Defendants have levied serious accusations against me and my firm in
25 writing and verbally, on top of failing and refusing to abide by the clear payment and
26 conduct obligations set forth in the engagement agreement and instructing that I make
27 filings with the Court that are not consistent with my ethical duties and Rule 11 of the
28

3
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1 FRCP. In addition, Defendants have announced they are not obligated to comply with
2 and do not intend to comply with the payment obligations going forward.
3 9. Defendants have instructed counsel to file certain documents that such
4 clients prepared without the benefit of counsel, and that, upon review, fall far short of
5 the professional standards required by the Court of my firm. I have not and would not
6 sign and file these papers with the Court and could not certify them as appropriate
7 papers in compliance with my duties under Rule 11. The Defendants even attempted
8 to file such documents with this Court without my permission or signature, but such
9 papers were rejected by the Court Clerk.
10 10. Defendants have exhausted their legal retainer, and have failed to make
12300 Wilshire Boulevard, Suite 210

11 payments when due, and announced their intention not comply with payment
CORRIGAN & MORRIS LLP

12 obligations in the future.


Los Angeles, CA 90025

13 11. On December 10, 2018, I notified the Defendants via email, in an


14 exchange which verified Defendants’ receipt of such email, that pursuant to
15 California Rule of Professional Conduct 1.16, my firm must terminate the
16 engagement and Defendants had two-weeks to find substitute counsel. If Defendants
17 did not find substitute counsel, then I would seek the Court’s permission to withdraw.
18 I also attached a copy of the draft answer and affirmative defenses to the complaint
19 that we were prepared to file if replacement counsel were not located by the
20 December 17, 2018, the response date stipulated to with Plaintiff.
21 12. On December 11, 2018, I reminded the Defendants via email to Mr.
22 Ringgold of the upcoming deadline to substitute C&M out of the case with new
23 counsel. Mr. Ringgold replied to that email disputing C&M’s right to terminate the
24 engagement. I replied to him advising that he would have two-weeks to locate
25 replacement counsel and, if not, I would bring a motion to withdraw.
26 13. I continued to work on the case, including preparing an extensive
27 Answer and Affirmative Defenses to the Securities and Exchange Commission’s
28 lengthy Complaint, because such answer was due on or around December 20, 2018.

4
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1 14. On December 14, 2018, I sent an email reminding Mr. Ringgold of the
2 need to find replacement counsel and enclosed an executed substitution of counsel
3 form for his convenience. Mr. Ringgold responded with threats against me.
4 15. At my clients’ direction, on December 17, 2018, notwithstanding the
5 breakdown in client relationship and my December 10, 2018 notice to Defendants, I
6 sought to protect Defendants’ legal interest, and I filed an Answer with Affirmative
7 Defenses to the SEC’s Complaint on December 17, 2018. I also sent a copy of the
8 Answer and Affirmative Defenses to Mr. Ringgold and reminded him that my firm
9 would file a motion to withdraw if replacement counsel had not substituted into the
10 case by the deadline or approximately December 24, 2018.
12300 Wilshire Boulevard, Suite 210

11 16. The undersigned counsel believes in good faith that neither he nor his
CORRIGAN & MORRIS LLP

12 firm can continue to represent Defendants while complying with California Rules of
Los Angeles, CA 90025

13 Professional Responsibility and therefore further representation is impermissible


14 under the California Rules of Conduct.
15 17. It is still very early in the case and no scheduling order or trial date has
16 been set by this Court yet. I have served a copy of these papers on the Defendants as
17 described in the proof of service filed herewith.
18 I declare under penalty of perjury under the laws of the United States that the
19 foregoing is true and correct and that this declaration was executed in Los Angeles,
20 California this 27th day of December 2018.
21
22 /s/Stanley C. Morris
23
24
25
26
27
28

5
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1
2
3
4
5
6
7
8
9 UNITED STATES DISTRICT COURT
10 SOUTHERN DISTRICT OF CALIFORNIA
11 Case No.: 18-CV-2287-GPC (MSB)
12
[PROPOSED] ORDER
13 SECURITIES AND EXCHANGE
COMMISSION, GRANTING MOTION TO
14 WITHDRAW AS COUNSEL FOR
Plaintiff, DEFENDANTS REGINALD B
15
vs. RINGGOLD AND BLOCKVEST
16 LLC
BLOCKVEST, LLC, and REGINALD
17 BUDDY RINGGOLD, III aka RASOOL
ABDUL RAHIM EL, Date: March 8, 2019
18 Time: 1:30 p.m.
Defendants.
19 Place: Courtroom 2D (2nd Floor -
20 Schwartz), Suite 2190
221 West Broadway
21 San Diego, CA 92101
22
23 Judge: Hon. Gonzalo P. Curiel

24 Complaint Filed:
25 OCTOBER 3, 2018
26
27
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1
Case 3:18-cv-02287-GPC-MSB Document 47-2 Filed 12/27/18 PageID.3225 Page 2 of 2

1 This matter came before the Court on the Motion of Stanley C. Morris and
2 Corrigan & Morris, LLP, Counsel of record for Defendants Reginald B. Ringgold, III
3 and Blockvest LLC (“Defendants”) for an order to withdraw as counsel, filed
4 December 27, 2018.
5 The Court has considered the moving and any opposition documents submitted
6 in connection with this motion. For the reasons and in the manner set forth below, the
7 Court hereby GRANTS Stanley C. Morris’ and Corrigan & Morris LLP’s Motion to
8 Withdraw as Counsel to the Defendants.
9 Counsel’s Declaration represented that further legal services are precluded
10 because there is a breach of the attorney-client engagement agreement and a complete
11 breakdown in the attorney-client relationship. Declaration of Stanley C. Morris at ¶¶
12 3, 7-9. Counsel’s Declaration further represented that Counsel complied with Local
13 Rules 83.3(f)(3) and 83.4 and California Rule of Professional Conduct 1.16.
14 Having reviewed and considered the matter, and for good cause shown, the
15 Motion to Withdraw as Counsel for the Defendants is hereby GRANTED. This
16 Order shall be effective immediately.
17
18 IT IS SO ORDERED:
19 DATE: December 2018
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21
________________________________
22 GONZALO P. CURIEL
23 UNITED STATES DISTRICT COURT
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Case 3:18-cv-02287-GPC-MSB Document 47-3 Filed 12/27/18 PageID.3226 Page 1 of 2

1 CORRIGAN & MORRIS, LLP


Brian T. Corrigan (Cal Bar No. 143188)
2 bcorrigan@cormorllp.com
Stanley C. Morris (Cal Bar No. 183620)
3 scm@cormorllp.com
12300 Wilshire Boulevard, Suite 210
4 Los Angeles, CA 90025
Telephone: (310) 394-2800
5 Facsimile: (310) 394-2825
6 Attorneys for Defendants
BLOCKVEST, LLC, and REGINALD
7 BUDDY RINGGOLD, III aka RASOOL
ABDUL RAHIM EL
8
9
10
12300 Wilshire Boulevard, Suite 210

11
CORRIGAN & MORRIS LLP

UNITED STATES DISTRICT COURT


Los Angeles, CA 90025

12
13 SOUTHERN DISTRICT OF CALIFORNIA
14
15 SECURITIES AND EXCHANGE Case No.: 18-CV-2287-GPC (BLM)
COMMISSION,
16 Judge: Hon. Gonzalo P. Curiel
Plaintiff,
17
vs.
18 PROOF OF SERVICE
BLOCKVEST, LLC, and REGINALD
19 BUDDY RINGGOLD, III aka RASOOL
ABDUL RAHIM EL,
20
Defendants.
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Case 3:18-cv-02287-GPC-MSB Document 47-3 Filed 12/27/18 PageID.3227 Page 2 of 2

1 PROOF OF SERVICE

2 I am employed in the County of Los Angeles. I am over the age of 18 and not a party to the
within action; my business address is 12300 Wilshire Blvd., Suite 210, Los Angeles, CA 90025
3 On December 27, 2018, I served the foregoing documents described as:
4
1) CORRIGAN & MORRIS LLP MOTION TO WITHDRAW AS COUNSEL TO
5 DEFENDANTS

6 2) DECLARATION OF STANLEY C. MORRIS IN SUPPORT OF MOTION TO


WITHDRAW AS COUNSEL TO DEFENDANTS
7
8 3) PROPOSED ORDER GRANTING MOTION TO WITHDRAW

9 SERVED UPON:
REGINALD B. RINGGOLD, III
10 Chairman of Blockvest, LLC
11 7320 Santa Monica Blvd, Suite 301
12300 Wilshire Boulevard, Suite 210

West Hollywood, CA 90046


CORRIGAN & MORRIS LLP

12 chairman@blockvestico.io
Los Angeles, CA 90025

13 AMY J. LONGO, Esq.


Email: longoa@sec.gov
14 DAVID S. BROWN, Esq.
15 Email: browndav@sec.gov
BRENT W. WILNER, Esq.
16 Email: wilnerb@sec.gov
Attorneys for Plaintiff
17 Securities and Exchange Commission
18 [XX] BY ELECTRONIC MAIL
19 I caused the foregoing document to be served via electronic mail to the email
addresses above.
20
[XX] VIA U.S. MAIL
21 I caused the foregoing documents to be served by mail to Mr. Reginald Ringgold, III.
22
I declare under penalty of perjury under the laws of the United States of
23 America that the above is true and correct.
24 Executed on December 27, 2018, at Los Angeles, California
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/s/ Stanley C. Morris
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