On November 03, 2020 a
Party Notice
was filed
involving a dispute between
American Express National Bank,
and
Ephraim, James,
for Contract - Consumer/Commercial/Debt
in the District Court of Fort Bend County.
Preview
NO.
AMERICAN EXPRESS NATIONAL IN THE DISTRICT COURT
BANK
Plaintiff 400TH JUDICIAL DISTRICT
JAMES EPHRAIM FORT BEND COUNTY, TEXAS
Defendant(s)
NOTICE OF WITHDRAWAL OF DAWN ROGERS COUNSEL
DESIGNATION OF NEW ATTORNEY IN CHARGE
DAWN D. ROGERS, movant, brings this Motion for Withdrawal of Counsel pursuant to
TRCP 1 and in support shows the following:
I. IDENTIFICATION OF MOVANT
Dawn Rogers, movant, is the attorney of record for Plaintiff.
II. GOOD CAUSE FOR WITHDRAWAL
Good cause exists for Dawn Rogers withdraw as counsel in that Movant has been elected
Judge in Harris County, Texas and can no longer practice law. Movant will no longer be
an attorney for Plaintiff’s firm, Zwicker and Associates, P.C. effective December 23, 2020.
III. DESIGNATION OF NEW ATTORNEY IN CHARGE
American Express National Bank, wishes to remove Dawn Rogers as attorney in charge
and designate Johnetta Lang as attorney in charge of this case
Johnetta Lang is already listed as an attorney of record for this case. Her contact phone
number, address, fax number and email address are identical to that of Movant Dawn
Rogers. As attorney in charge, he will be responsible for this case and will be the attorney
who receives all communications from the Court and other parties per TRCP
American Express National Bank, designates Johnetta Lang as attorney in charge.
IV. CLIENT CONSENT
Plaintiff has consent to the withdrawal of Dawn Rogers as counsel and designation of
Johnetta Lang as attorney in charge.
V. LAST KNOW ADDRESS OF DEFENDANT/OPPOSING COUNSEL
7. The last known address of Defendant or opposing counsel is as follows:
KELVINA WILEY
4265 SAN FELIPE STREET
STE 1100
HOUSTON, TX 77469
KWILEY@WILEYLEGALTX.COM
VI. NOTICE TO CLIENT/PARTIES
8. Notice of this withdrawal and designation has been provided to all other parties, as required
by Texas Rule of Civil Procedure 21a. Parties will continue to be notified of all settings
and/or deadlines as Movant’s withdrawal will in no way impact the litigation of this matter
as there are a total of three attorneys for Plaintiff on this case.
VII. NO DELAY TO LITIGATION
9. This Motion for Withdrawal is not sought for the purpose of delay and will cause no harm
to either party.
PRAYER
Movant prays that the Court enter an order discharging movant, Dawn D. Rogers as Counsel and
attorney of record for this case.
Respectfully submitted,
Zwicker & Associates, P.C.
A Law Firm Engaged in Debt Collection
Attorneys for Plaintiff
14090 South West Freeway, Suite 408
Sugar Land, TX 77478
(281) 494-0300
(281) 494-0213 fax
jolang@zwickerpc.com
By: /s/ Dawn D. Rogers
Dawn Rogers
State Bar Number 24037383
AGREED AS TO FORM AND SUBSTANCE:
/s/ Johnetta Lang
Johnetta Lang
State Bar Number 24036943
CERTIFICATE OF SERVICE
I hereby certify that on the ____ day of December, 2020, this office served a true and correct
copy of the foregoing in accordance with the Rule 21a of the Texas Rules of Civil Procedure
upon the below listed interested part [ ] First Class Mail
[ ] E Service
[ ] Certified Mail Return Receipt
Requested
KELVINA WILEY
4265 SAN FELIPE STREET
STE 1100
HOUSTON
KWILEY@WILEYLEGALTX.COM
/s/ Dawn D. Rogers________________
DAWN D. ROGERS
Document Filed Date
December 30, 2020
Case Filing Date
November 03, 2020
Category
Contract - Consumer/Commercial/Debt
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NO. AMERICAN EXPRESS NATIONAL IN THE DISTRICT COURT BANK Plaintiff 400TH JUDICIAL DISTRICT JAMES EPHRAIM FORT BEND COUNTY, TEXAS Defendant(s) NOTICE OF WITHDRAWAL OF DAWN ROGERS COUNSEL DESIGNATION OF NEW ATTORNEY IN CHARGE DAWN D. ROGERS, movant, brings this Motion for Withdrawal of Counsel pursuant to TRCP 1 and in support shows the following: I. IDENTIFICATION OF MOVANT Dawn Rogers, movant, is the attorney of record for Plaintiff. II. GOOD CAUSE FOR WITHDRAWAL Good cause exists for Dawn Rogers withdraw as counsel in that Movant has been elected Judge in Harris County, Texas and can no longer practice law. Movant will no longer be an attorney for Plaintiff’s firm, Zwicker and Associates, P.C. effective December 23, 2020. III. DESIGNATION OF NEW ATTORNEY IN CHARGE American Express National Bank, wishes to remove Dawn Rogers as attorney in charge and designate Johnetta Lang as attorney in charge of this case Johnetta Lang is already listed as an attorney of record for this case. Her contact phone number, address, fax number and email address are identical to that of Movant Dawn Rogers. As attorney in charge, he will be responsible for this case and will be the attorney who receives all communications from the Court and other parties per TRCP American Express National Bank, designates Johnetta Lang as attorney in charge. IV. CLIENT CONSENT Plaintiff has consent to the withdrawal of Dawn Rogers as counsel and designation of Johnetta Lang as attorney in charge. V. LAST KNOW ADDRESS OF DEFENDANT/OPPOSING COUNSEL 7. The last known address of Defendant or opposing counsel is as follows: KELVINA WILEY 4265 SAN FELIPE STREET STE 1100 HOUSTON, TX 77469 KWILEY@WILEYLEGALTX.COM VI. NOTICE TO CLIENT/PARTIES 8. Notice of this withdrawal and designation has been provided to all other parties, as required by Texas Rule of Civil Procedure 21a. Parties will continue to be notified of all settings and/or deadlines as Movant’s withdrawal will in no way impact the litigation of this matter as there are a total of three attorneys for Plaintiff on this case. VII. NO DELAY TO LITIGATION 9. This Motion for Withdrawal is not sought for the purpose of delay and will cause no harm to either party. PRAYER Movant prays that the Court enter an order discharging movant, Dawn D. Rogers as Counsel and attorney of record for this case. Respectfully submitted, Zwicker & Associates, P.C. A Law Firm Engaged in Debt Collection Attorneys for Plaintiff 14090 South West Freeway, Suite 408 Sugar Land, TX 77478 (281) 494-0300 (281) 494-0213 fax jolang@zwickerpc.com By: /s/ Dawn D. Rogers Dawn Rogers State Bar Number 24037383 AGREED AS TO FORM AND SUBSTANCE: /s/ Johnetta Lang Johnetta Lang State Bar Number 24036943 CERTIFICATE OF SERVICE I hereby certify that on the ____ day of December, 2020, this office served a true and correct copy of the foregoing in accordance with the Rule 21a of the Texas Rules of Civil Procedure upon the below listed interested part [ ] First Class Mail [ ] E Service [ ] Certified Mail Return Receipt Requested KELVINA WILEY 4265 SAN FELIPE STREET STE 1100 HOUSTON KWILEY@WILEYLEGALTX.COM /s/ Dawn D. Rogers________________ DAWN D. ROGERS