Motion,Ex Parte: SHAWN SMITH vs. ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY, et al

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                                FILED
                                                                                                          4/18/2023 5:13 PM
                                                                                                              FELICIA PITRE
                                                                                                           DISTRICT CLERK
                                                                                                        DALLAS CO., TEXAS
                                                                                                     Steve Brashear DEPUTY


                                   CAUSE NO. DC-23-00793
SHAWN SMITH;                                                            THE DISTRICT COURT OF




                                                 §§§§§§§§§§§
                                                                   IN

       Plaintiff,

VS.                                                                     DALLAS COUNTY, TEXAS
ALLSTATE FIRE AND CASUALTY
INSURANCE COMPANY; AND
CHRISTIE LYNN GIBSON;

       Defendants.                                                      101 ST   JUDICIAL DISTRICT


                    P_LAINTIFF'S MOTION TO SU_BSTITlfi COUNSE_L

Plaintiff Shawn Smith files this motion to substitute Kristofor Heald of Witherite Law

Group, PLLC as counsel of record for Plaintiff in place of Adam            J.    Flood formerly of

Witherite Law Group, PLLC, and respectfully shows the Court as follows:

       The substitution of counsel is      in the Plaintiff's best interest and with her     consent.

Plaintiff's prior attorney, Adam   J.   Flood, is no longer employed by Witherite Law Group,

PLLC, and is   no longer counsel of record in this case and should be removed from the

service list. The lawsuit was filed on January 18, 2023. There will be no delay as a

result of this substitution. Kristofor Heald's contact and service information follows:

                                        Kristofor Heald
                                        Witherite Law Group, PLLC
                                        State Bar No. 24058770
                                        kris.heald@witheritelawcom
                                        10440 N. Central Expressway
                                        Suite 400
                                        Dallas, TX 75231-2228
                                        Telephone: 214-864-9612
                                        Fax: 214-378-6670

       WHEREFORE, premises considered, Plaintiff prays that the substitution                  be

allowed and for such other and further relief to which Plaintiff may be justly entitled.



PLAINTIFF'S MOTION TO SUBSTITUTE COUNSEL — Page                1
                               Respectfully submitted,

                               WITHERITE LAW GROUP, PLLC

                           BY: /s/ Kristofor Heald
                               KRISTOFOR HEALD
                               State Bar No. 24058770
                               Kris.Heald@witheritelaw.com
                               10440 N. Central Expressway
                               Suite 400
                               Dallas, TX 75231-2228
                               214/864-9612
                               214/378-6670 (fax)

                               ATTORNEY FOR PLAINTIFF




PLAINTIFF'S MOTION TO SUBSTITUTE COUNSEL — Page 2
                                QRTIFICATE 0F SERVICE
       |
           hereby certify that a true and correct copy of the foregoing has been fon/varded

to all counsel of record on this 18th day of April, 2023, pursuant to the Texas Rules of

Civil Procedure.

                                            /s/ Kristofor Heald
                                            Kristofor Heald

John W. Stilwell
Law Office of John Stilwell
6213 Chapel Hill Road Boulevard
Suite B
Plano, Texas 75093




PLAINTIFF'S MOTION TO SUBSTITUTE COUNSEL — Page 3
                         Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Javier Rangel on behalf of Kristofor Heald
Bar No. 24058770
Javier. Rangel@witheritelaw.com
Envelope ID: 74781026
Filing Code Description: Motion - Substitution Of Counsel
Filing Description:
Status as of 4/19/2023 2:51 PM CST

Associated Case Party: ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY

Name            BarNumber   Email                       TimestampSubmitted     Status
John Stilwell               john@stilwelldallas.com     4/18/2023 5:13:31 PM   SENT
Athena Hord                 Athena@stilwelldallas.com   4/18/2023 5:13:31 PM   SENT


Case Contacts

Name                BarNumber   Email                                  Timestam pSubmitted     Status
ADAM JFLOOD                     ADAM.FLOOD@WITHERITELAW.COM            4/18/2023 5:13:31 PM    SENT


Associated Case Party: SHAWN SMITH

Name                BarNumber   Email                        TimestampSubmitted       Status
Kristofor S.Heald               Kris.Heald@EWlawyers.com     4/18/2023 5:13:31 PM     ERROR