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Evans
Telephone: (770) 443-4108 Facsimile: (770) 443-9013 e-mail: JLELegal@aol.com mobile: (404) 862-4705
Treva Shelton, Clerk Paulding County Superior Court 280 Constitution Blvd. Room 1028 Dallas, GA 30132
Re: Freeman v. Todd Paulding County Superior Court Civil Action No:12-CV-1077-TB
Dear Ms. Shelton: Enclosed please find the Original and one copy of Ms. Evans' Motion to Withdraw, along with proposed Order Granting Motion to Withdraw in this matter. Please file the Original with the Court and return a file-stamped copy in the provided self-addressed and stamped envelope, and submit the Order to the Judge for his review. If you have any questions, please contact the office at (770) 443-4108. Thank you so much for your assistance in this matter. Yours Truly,
MOTION FOR WITHDRAWAL OF COUNSEL Comes now Jana L. Evans, counsel of record for Plaintiff herein, and pursuant to Uniform Superior Court Rule 4.3(1), requests that the Court permit her to withdraw from representation of Plaintiff herein, GILBERT FREEMAN, JR. This request is made after the verbal request of Plaintiff herein on March 29 th , 2013, followed by a formal written request on April 6 th , 2013 expressly directing Counsel to withdraw. Counsel has previously notified Plaintiff as follows: (1) Counsel wishes to withdraw from representation of Plaintiff for the following reasons: (2) (3) The Paulding County Superior Court shall retain jurisdiction of this action; Plaintiff, GILBERT FREEMAN, JR., has the burden of keeping the court informed concerning where notices, pleadings or other papers may be served upon him;
(4)
Plaintiff, GILBERT FREEMAN, JR., has the obligation to prepare for trial or to hire other counsel to prepare for trial when the trial date has been set.
(5)
That if Plaintiff, GILBERT FREEMAN, JR., fails or refuses to meet these burdens, Plaintiff may suffer adverse consequences;
(6)
The dates of any scheduled proceedings, including trial, will not be affected by the withdrawal of counsel;
(7)
Service of notices may be made upon Plaintiff, GILBERT FREEMAN, JR., at Plaintiff's last known address:
(8)
This case has not been scheduled for trial, and there is no expectation that the granting of this Motion would result in a delay of the trial of this matter.
CONCLUSION
WHEREFORE, Plaintiff's counsel urges the Court to grant her motion to withdraw from this matter. Respectfully submitted this 8 th day of April, 2013.
LAW OFFICE OF JANA L. EVANS 355 Camden Woods Drive Dallas, GA 30157 (770) 443-4108 e-mail: jlelegal@aol.com ara L. Evans d Bar No. 200090
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GILBERT FREEMAN, JR., Plaintiff, vs. JODY EBRIGHT TODD, Defendant. CIVIL ACTION FILE NO. 12-CV-1077-TB
CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing Plaintiff's Counsel's Motion for Withdrawal, by placing the same in the United States Mail addressed to Plaintiff and Defendant's counsel, postage prepaid, as follows:
Parisa N. Herrin, Esq. The Herrin Law Firm, PC 19 Trammell Street Marietta, GA 30064
L EVANS ar No. 200090 355 Camden Woods Drive Dallas, GA 30157 phone (770) 443-4108 e-mail: jlelegal@aol.com AND jlelegal2aol.com
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, 2013.
Presented by: