On August 24, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Taylor, Beverly,
Taylor, Freddie,
and
Chuy Roofing,
Gutierrez, Jesus,
Peaceful Hope Baptist Church,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
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FILED
8/20/2021 1:19 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez DEPUTY
CAUSE NO. DC-18-11857
FREDDIE TAYLOR and, IN THE DISTRICT COURT OF
§§§§§§§§§§§§§
BEVERLY TAYLOR,
Plaintiffs,
V.
DALLAS COUNTY, TEXAS
PEACEFUL HOPE BAPTIST CHURCH;
CHUY ROOFING; JESUS GUTIERREZ
d/b/a CHUY ROOFING; and JESUS
GUTIERREZ.
Defendants. 134TH JUDICIAL DISTRICT
PLAINTIFF’S MOTION T0 WITHDRAW
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff, FREDDIE TAYLOR and BEVERLY TAYLOR, by and through the undersigned
attorney files this Plaintiff‘s Motion to Withdraw. In support thereof, Plaintiff would respectfully
show the Court the following:
INTRODUCTION
1. Plaintiff, Freddie Taylor and Beverly Taylor, sued defendants, Chuy Roofing; Jesus
Gutierrez d/b/a Chuy Roofing; and Jesus Gutierrez, for injuries as a result of a motor vehicle
collision on or about July 1, 2017.
BACKGROUND
2. Plaintiff filed a lawsuit on June 1, 2019.
3. Trial is set for September 27, 2021.
ARGUMENT & AUTHORITIES
4. As required by Texas Rule of Civil Procedure 10, there is good cause for this Court to
grant this Motion to Withdraw.
5. Plaintiff Counsel has made numerous attempts and performed due diligence in trying
to get in contact with Plaintiff. Our firm has been unable to reach Plaintiffs.
PRAYER
6. For these reasons, Plaintiff asks this Court to grant the Motion to Withdraw a Plaintiff
prays for all other and such relief, both law and in equity, to which Plaintiff may be justly entitled
to receive.
Respectfully submitted this 20‘“ day of August 2021
KELLEY LAW FIRM
BY: /s/ Dagmawi Getachew
Dagmawi Getachew, Esq.
DAGMAWI GETACHEW
Texas Bar No. 24108975
getachew@kelleyfirm.com
201 N. Harwood Street
Dallas, Texas 75201
Phone: (972) 850-0500
Fax: (972) 850-0400
ATTORNEY FOR PLAINTIFFS
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing Motion to Withdraw was
served on all counsel or record and/or pro se parties in accordance with Rules 21 and 21a of the
Texas Rules of Civil Procedure on this 20th day of August 2021.
/s/ Dagmawi Getachew
Dagmawi Getachew, Esq.
CAUSE NO. DC-18-11857
FREDDIE TAYLOR and, IN THE DISTRICT COURT OF
§§§§§§§§§§§§§
BEVERLY TAYLOR,
Plaintiffs,
V.
DALLAS COUNTY, TEXAS
PEACEFUL HOPE BAPTIST CHURCH;
CHUY ROOFING; JESUS GUTIERREZ
d/b/a CHUY ROOFING; and JESUS
GUTIERREZ.
Defendants. 134TH JUDICIAL DISTRICT
ORDER GRANTING PLAINTIFF'S MOTION TO WITHDRAW
On this day came to be heard Plaintiffs Motion to Withdraw in the above referenced
matter. It appears to the Court that the motion is well taken and should be granted.
IT IS FURTHER ORDERED that The Kelley Law Firm is hereby removed as the
attorney on the above matter.
Signed this day of , 20
JUDGE PRESIDING
Document Filed Date
August 20, 2021
Case Filing Date
August 24, 2018
Category
OTHER PERSONAL INJURY
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FILED 8/20/2021 1:19 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Darling Tellez DEPUTY CAUSE NO. DC-18-11857 FREDDIE TAYLOR and, IN THE DISTRICT COURT OF §§§§§§§§§§§§§ BEVERLY TAYLOR, Plaintiffs, V. DALLAS COUNTY, TEXAS PEACEFUL HOPE BAPTIST CHURCH; CHUY ROOFING; JESUS GUTIERREZ d/b/a CHUY ROOFING; and JESUS GUTIERREZ. Defendants. 134TH JUDICIAL DISTRICT PLAINTIFF’S MOTION T0 WITHDRAW TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff, FREDDIE TAYLOR and BEVERLY TAYLOR, by and through the undersigned attorney files this Plaintiff‘s Motion to Withdraw. In support thereof, Plaintiff would respectfully show the Court the following: INTRODUCTION 1. Plaintiff, Freddie Taylor and Beverly Taylor, sued defendants, Chuy Roofing; Jesus Gutierrez d/b/a Chuy Roofing; and Jesus Gutierrez, for injuries as a result of a motor vehicle collision on or about July 1, 2017. BACKGROUND 2. Plaintiff filed a lawsuit on June 1, 2019. 3. Trial is set for September 27, 2021. ARGUMENT & AUTHORITIES 4. As required by Texas Rule of Civil Procedure 10, there is good cause for this Court to grant this Motion to Withdraw. 5. Plaintiff Counsel has made numerous attempts and performed due diligence in trying to get in contact with Plaintiff. Our firm has been unable to reach Plaintiffs. PRAYER 6. For these reasons, Plaintiff asks this Court to grant the Motion to Withdraw a Plaintiff prays for all other and such relief, both law and in equity, to which Plaintiff may be justly entitled to receive. Respectfully submitted this 20‘“ day of August 2021 KELLEY LAW FIRM BY: /s/ Dagmawi Getachew Dagmawi Getachew, Esq. DAGMAWI GETACHEW Texas Bar No. 24108975 getachew@kelleyfirm.com 201 N. Harwood Street Dallas, Texas 75201 Phone: (972) 850-0500 Fax: (972) 850-0400 ATTORNEY FOR PLAINTIFFS CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Motion to Withdraw was served on all counsel or record and/or pro se parties in accordance with Rules 21 and 21a of the Texas Rules of Civil Procedure on this 20th day of August 2021. /s/ Dagmawi Getachew Dagmawi Getachew, Esq. CAUSE NO. DC-18-11857 FREDDIE TAYLOR and, IN THE DISTRICT COURT OF §§§§§§§§§§§§§ BEVERLY TAYLOR, Plaintiffs, V. DALLAS COUNTY, TEXAS PEACEFUL HOPE BAPTIST CHURCH; CHUY ROOFING; JESUS GUTIERREZ d/b/a CHUY ROOFING; and JESUS GUTIERREZ. Defendants. 134TH JUDICIAL DISTRICT ORDER GRANTING PLAINTIFF'S MOTION TO WITHDRAW On this day came to be heard Plaintiffs Motion to Withdraw in the above referenced matter. It appears to the Court that the motion is well taken and should be granted. IT IS FURTHER ORDERED that The Kelley Law Firm is hereby removed as the attorney on the above matter. Signed this day of , 20 JUDGE PRESIDING