On September 02, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Strom Aviation, Inc.,
and
Aviation Consulting Experts Inc,
J&J Robinson Ventures, L.L.C.,
Robinson Aircraft Interiors, Inc.,
Robinson, Jeffrey Wayne,
Robinson, Joe Wayne,
Wrolson, Daniel G,
for OTHER (CIVIL)
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
1/20/2017 6:33:46 PM
FELICIA PITRE
DISTRICT CLERK
Cause No. DC-16-11118
Strom Aviation, Inc., § In the District Court
Plaintiff, §
§
v. §
§
Jeffrey Wayne Robinson; Joe §
Wayne Robinson; Harbor §
America, Inc.; and Aviation §
Consulting Experts, Inc., §
Defendants, § 95th Judicial District Court
§
Robinson Aircraft Interiors, Inc., §
Defendant and Third-Party Plaintiff, §
§
v. §
§
Daniel G. Wrolson §
Third-Party Defendant. § Dallas County, Texas
Plaintiff’s Amended Motion to Withdraw and Substitute Counsel
Plaintiff Strom Aviation, Inc. (“Strom”) files this Amended Motion to Withdraw and
Substitute Counsel. In support, Strom shows the following.
Strom requests that its present counsel, listed below, be allowed to withdraw as
counsel for it in the above-styled lawsuit.
Thomas E. Kurth Debra J. McComas
State Bar No. 11768500 State Bar No. 00794261
Thomas.Kurth@haynesboone.com Debbie.McComas@haynesboone.com
David B. Rost
State Bar No. 24102431
David.Rost@haynesboone.com
HAYNES AND BOONE, LLP
2323 Victory Avenue, Suite 700
Dallas, Texas 75219
Telephone: 214-651-5000
Facsimile: 214-651-5940
If withdraw is granted, Strom will substitute the law firm Maris & Lanier, P.C. as its
counsel of record. Attorneys with Maris & Lanier, P.C. have already appeared as
1
additional counsel for Strom in this lawsuit.
Upon substitution, Strom designates Robert F. Maris as lead counsel and Brent Sedge
as additional counsel. Strom requests that all further communications be directed to its
substituted counsel. Strom seeks this withdraw and substitution in good faith and not for
purposes of delay. Defendants will not be prejudiced by the relief sought by this motion.
Respectfully submitted,
MARIS & LANIER, P.C.
/s/ Robert F. Maris
Robert F. Maris
State Bar No. 12986300
rmaris@marislanier.com
Brent D. Sedge
State Bar No. 24082120
bsedge@marislanier.com
3710 Rawlins Street, Suite 1550
Dallas, Texas 75219
214-706-0920 telephone
214-706-0921 facsimile
Attorneys for Plaintiff
Strom Aviation, Inc.
Certificate of Conference
Counsel for Strom has personally conducted a conference with counsel for all other
parties at which there was a substantive discussion of every item presented to the Court
in this motion. All counsel indicated that they are unopposed to the relief sought by this
motion. Certified on January 20, 2017.
/s/ Brent Sedge
Brent Sedge
2
Certificate of Service
In accordance with Texas Civil Procedure Rule 21a, I certify that I served the
foregoing document on January 20, 2017, on the following parties via eServe:
Carolyn Raines John R. Galvin
State Bar No. 00787852 State Bar No. 24032340
CRaines@GodwinLaw.com jrg@lbpcglobal.com
GODWIN BOWMAN & MARTINEZ LEWIS & BACKHAUS, P.C.
1201 Elm Street Suite 1700 5501 LBJ Freeway, Suite 800
Dallas, Texas 75270 Dallas, Texas 75240
(214) 939-4452 – Telephone (972) 233-8115 – Telephone
(214) 760-7332 – Facsimile (972) 692-5115 – Facsimile
Attorney for Defendants Robinson Attorney for Defendant
Aircraft Interiors, Inc., Aviation Harbor America, Inc.
Consulting Experts, Jeffrey Wayne
Robinson, and Joe Wayne Robinson.
W. Alan Wright
State Bar No. 22062700
alan.wright@kilpatrickownsend.com
KILPATRICK TOWNSEND & STOCKTON LLP
2001 Ross Avenue, Suite 4400
Dallas, Texas 75201
(214) 922-7100 – Telephone
(214) 922-7101 – Facsimile
Attorney for Third-Party Defendant
Daniel G. Wrolson
/s/ Brent Sedge
Brent Sedge
3
Document Filed Date
January 20, 2017
Case Filing Date
September 02, 2016
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FILED DALLAS COUNTY 1/20/2017 6:33:46 PM FELICIA PITRE DISTRICT CLERK Cause No. DC-16-11118 Strom Aviation, Inc., § In the District Court Plaintiff, § § v. § § Jeffrey Wayne Robinson; Joe § Wayne Robinson; Harbor § America, Inc.; and Aviation § Consulting Experts, Inc., § Defendants, § 95th Judicial District Court § Robinson Aircraft Interiors, Inc., § Defendant and Third-Party Plaintiff, § § v. § § Daniel G. Wrolson § Third-Party Defendant. § Dallas County, Texas Plaintiff’s Amended Motion to Withdraw and Substitute Counsel Plaintiff Strom Aviation, Inc. (“Strom”) files this Amended Motion to Withdraw and Substitute Counsel. In support, Strom shows the following. Strom requests that its present counsel, listed below, be allowed to withdraw as counsel for it in the above-styled lawsuit. Thomas E. Kurth Debra J. McComas State Bar No. 11768500 State Bar No. 00794261 Thomas.Kurth@haynesboone.com Debbie.McComas@haynesboone.com David B. Rost State Bar No. 24102431 David.Rost@haynesboone.com HAYNES AND BOONE, LLP 2323 Victory Avenue, Suite 700 Dallas, Texas 75219 Telephone: 214-651-5000 Facsimile: 214-651-5940 If withdraw is granted, Strom will substitute the law firm Maris & Lanier, P.C. as its counsel of record. Attorneys with Maris & Lanier, P.C. have already appeared as 1 additional counsel for Strom in this lawsuit. Upon substitution, Strom designates Robert F. Maris as lead counsel and Brent Sedge as additional counsel. Strom requests that all further communications be directed to its substituted counsel. Strom seeks this withdraw and substitution in good faith and not for purposes of delay. Defendants will not be prejudiced by the relief sought by this motion. Respectfully submitted, MARIS & LANIER, P.C. /s/ Robert F. Maris Robert F. Maris State Bar No. 12986300 rmaris@marislanier.com Brent D. Sedge State Bar No. 24082120 bsedge@marislanier.com 3710 Rawlins Street, Suite 1550 Dallas, Texas 75219 214-706-0920 telephone 214-706-0921 facsimile Attorneys for Plaintiff Strom Aviation, Inc. Certificate of Conference Counsel for Strom has personally conducted a conference with counsel for all other parties at which there was a substantive discussion of every item presented to the Court in this motion. All counsel indicated that they are unopposed to the relief sought by this motion. Certified on January 20, 2017. /s/ Brent Sedge Brent Sedge 2 Certificate of Service In accordance with Texas Civil Procedure Rule 21a, I certify that I served the foregoing document on January 20, 2017, on the following parties via eServe: Carolyn Raines John R. Galvin State Bar No. 00787852 State Bar No. 24032340 CRaines@GodwinLaw.com jrg@lbpcglobal.com GODWIN BOWMAN & MARTINEZ LEWIS & BACKHAUS, P.C. 1201 Elm Street Suite 1700 5501 LBJ Freeway, Suite 800 Dallas, Texas 75270 Dallas, Texas 75240 (214) 939-4452 – Telephone (972) 233-8115 – Telephone (214) 760-7332 – Facsimile (972) 692-5115 – Facsimile Attorney for Defendants Robinson Attorney for Defendant Aircraft Interiors, Inc., Aviation Harbor America, Inc. Consulting Experts, Jeffrey Wayne Robinson, and Joe Wayne Robinson. W. Alan Wright State Bar No. 22062700 alan.wright@kilpatrickownsend.com KILPATRICK TOWNSEND & STOCKTON LLP 2001 Ross Avenue, Suite 4400 Dallas, Texas 75201 (214) 922-7100 – Telephone (214) 922-7101 – Facsimile Attorney for Third-Party Defendant Daniel G. Wrolson /s/ Brent Sedge Brent Sedge 3