On August 15, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Kroesche, Martin,
Wassar Logistics Holdings Llc,
Schonefeld, Steve,
and
Dempsey, George,
Genesis Park,
Grisham Capital Llc,
Jrbs Engterprises,
Kroesche, Martin,
Loefffler, Court,
Massey, Glenn,
Shaper, Peter,
Wassar Logistics Holdings,
Wassar Logistics Inc,
for Debt/Contract - Debt/Contract
in the District Court of Harris County.
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CAUSE NUMBER 2016-54111
WASSAR LOGISTICS HOLDINGS, § IN THE DISTRICT COURT OF
LLC,
Plaintiff, §
§
§
§
MARTIN KROESCHE §
Defendant/Third-Party Plaintiff §
§ HARRIS COUNTY, TEXAS
§
§
PETER SHAPER, COURTLAND §
LOEFLER, GLENN MASSEY, STEVE §
SCHONEFELD, GEORGE DEMPSEY, §
GENESIS PARK, JRBS ENTERPRISES, §
LTD., GRISHAM CAPITAL, LLC, §
Third Party Defendants. § 333 JUDICIAL DISTRICT
OTION TO ITHDRAW OUNSEL
AND UBSTITUTE TTORNEY -CHARGE
COMES NOW, Martin Kroesche and moves for the Court to withdraw
Paul Anderson as counsel of record for Kroesche and substitute Paul Kirklin
of The Kirklin Law Firm, P.C. as attorney- -charge. In support, Kroesche
would show the Court as follows:
There is good cause for this Court to allow Paul Anderson to withdraw
as counsel of record for Kroesche. Mr. Anderson no longer represents
Kroesche in this case. Kroesche is represented by other able counsel in this
matter as he has retained The Kirklin Law Firm, P.C. to represent him in this
P age
suit. Kroesche requests, therefore, that Mr. Anderson be withdrawn as his
counsel of record in this case and that Paul Kirklin be substituted as attorney-
in-charge.
Kroesche approves of the withdrawal and substitution. Kroesche has
been notified in writing of his right to object to the motion and he consent to
this motion. Kroesche has been notified of all pending settings and deadlines.
This motion to withdraw as counsel of record and substitute counsel and
attorney-in-charge is not brought for the purpose of delay.
WHEREFORE, PREMISES CONSIDERED, Kroesche and Paul
Anderson prays that this Motion be in all things granted.
Respectfully submitted,
/s/ Paul V. Anderson
Paul V. Anderson
anderson@at-legal.com
SBOT No. 24089964
Anderson & Tillman, PLLC
3548 NE Stallings Dr.
Nacogdoches, TX 75965
(936) 305-3586
(713) 239-1489 – Fax
Previous Attorney for Kroesche
/s/ Paul S. Kirklin
Paul S. Kirklin
pkirklin@kirklinlaw.com
SBOT No. 24070063
The Kirklin Law Firm, P.C.
12600 N Featherwood Dr, Suite 225
Houston, TX 77034
2|P age
(713) 571-8300
(281) 922-6240 – Fax
Current Attorney for Kroesche
CERTIFICATE OF SERVICE
I certify that a copy of this instrument was electronically served on the
attorneys of record in this case including to Paul Dobrowski at
pjd@doblaw.com and Cody Stafford at cstafford@doblaw.com on January
12, 2017.
/s/ Paul V. Anderson
Paul V. Anderson
3|P age
Document Filed Date
January 12, 2017
Case Filing Date
August 15, 2016
Category
Debt/Contract - Debt/Contract
Status
Case On Appeal - Civil
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CAUSE NUMBER 2016-54111 WASSAR LOGISTICS HOLDINGS, § IN THE DISTRICT COURT OF LLC, Plaintiff, § § § § MARTIN KROESCHE § Defendant/Third-Party Plaintiff § § HARRIS COUNTY, TEXAS § § PETER SHAPER, COURTLAND § LOEFLER, GLENN MASSEY, STEVE § SCHONEFELD, GEORGE DEMPSEY, § GENESIS PARK, JRBS ENTERPRISES, § LTD., GRISHAM CAPITAL, LLC, § Third Party Defendants. § 333 JUDICIAL DISTRICT OTION TO ITHDRAW OUNSEL AND UBSTITUTE TTORNEY -CHARGE COMES NOW, Martin Kroesche and moves for the Court to withdraw Paul Anderson as counsel of record for Kroesche and substitute Paul Kirklin of The Kirklin Law Firm, P.C. as attorney- -charge. In support, Kroesche would show the Court as follows: There is good cause for this Court to allow Paul Anderson to withdraw as counsel of record for Kroesche. Mr. Anderson no longer represents Kroesche in this case. Kroesche is represented by other able counsel in this matter as he has retained The Kirklin Law Firm, P.C. to represent him in this P age suit. Kroesche requests, therefore, that Mr. Anderson be withdrawn as his counsel of record in this case and that Paul Kirklin be substituted as attorney- in-charge. Kroesche approves of the withdrawal and substitution. Kroesche has been notified in writing of his right to object to the motion and he consent to this motion. Kroesche has been notified of all pending settings and deadlines. This motion to withdraw as counsel of record and substitute counsel and attorney-in-charge is not brought for the purpose of delay. WHEREFORE, PREMISES CONSIDERED, Kroesche and Paul Anderson prays that this Motion be in all things granted. Respectfully submitted, /s/ Paul V. Anderson Paul V. Anderson anderson@at-legal.com SBOT No. 24089964 Anderson & Tillman, PLLC 3548 NE Stallings Dr. Nacogdoches, TX 75965 (936) 305-3586 (713) 239-1489 – Fax Previous Attorney for Kroesche /s/ Paul S. Kirklin Paul S. Kirklin pkirklin@kirklinlaw.com SBOT No. 24070063 The Kirklin Law Firm, P.C. 12600 N Featherwood Dr, Suite 225 Houston, TX 77034 2|P age (713) 571-8300 (281) 922-6240 – Fax Current Attorney for Kroesche CERTIFICATE OF SERVICE I certify that a copy of this instrument was electronically served on the attorneys of record in this case including to Paul Dobrowski at pjd@doblaw.com and Cody Stafford at cstafford@doblaw.com on January 12, 2017. /s/ Paul V. Anderson Paul V. Anderson 3|P age