On May 02, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Allen, Yolanda M,
and
Habash, Sami,
Neo Proteus Llc,
Sahoury, Christine,
Sams, Clayton,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
6/1 3/2019 1:34 PM
FELICIA PITRE
D'STR'CT CLERK
CAUSE N0. DC-19-06208
Terri Kilgore
YOLANDA ALLEN § IN THE DISTRICT COURT
§
Plaintiff, §
§
§
V. § 160th JUDICIAL DISTRICT
§
SAMI HABASH and §
CHRISTINE SAHOURY §
§
§
§
§
§
§
Defendants. § DALLAS COUNTY, TEXAS
UNOPPOSED MOTION TO WITHDRAW
COMES NOW, Yolanda M. Allen, Plaintiff in the above styled and referenced
cause, and Ciarochi Law Firm, PLLC and files this Unopposed Motion t0 Withdraw and
respectfully shows this Court as follows:
I.
Basis for Motion
Plaintiff and her attorney have discussed this matter and have made the decision that the
client’s interests are best served if an order of withdrawal is entered.
This motion is unopposed — both Yolanda Allen (see attached letter) and Counsel for
Defendants have indicated that they d0 not oppose this motion.
There is not discovery between the parties that has a current response due date.
II.
Updated Contact Information for Yolanda
Yolanda Allen presently has the following contact information:
UNOPPOSED MOTION TO WITHDRAW 1
Yolanda Allen
1623 S. Westmoreland
Glenn Heights, TX 75 1 54
(469) 337-3624
ymallen24@gmail.com
III. Conclusion/Request for Relief
Plaintiff Yolanda Allen and Ciarochi Law Firm PLLC request that this Court
enter an order granting the withdrawal 0f Ciarochi Law Firm PLLC from representation
in this case and that the Court take note 0f the contact information for Yolanda Allen for
future notices.
Respectfully submitted,
/s/ Jason Charles Ciarochi
Jason Charles Ciarochi
State Bar No. 24012424
Ciarochi Law Firm, PLLC
P.O. Box 29256
Dallas, Texas 75229
Phone: 214-642-2424
Fax: 2 14-242-2791
jason@ciarochilaw.com
ATTORNEY FOR PLAINTIFF
YOLANDA ALLEN
CERTIFICATE OF CONFERENCE
Plaintiff and Ciarochi Law Firm PLLC have discussed this Motion and are in
agreement that the motion should be filed and hope that the Court Will enter an order 0f
withdrawal. Defendants’ Counsel is aware of the Motion (has been emailed a copy 0f the
motion) and has indicated that Defendants do not oppose the motion.
UNOPPOSED MOTION TO WITHDRAW 2
/s/ Jason Charles Ciarochi
Jason Charles Ciarochi
CERTIFICATE OF SERVICE
A copy 0f this filing has been sent t0 all parties in accordance with the Texas
Rules of Civil Procedure on the date it was filed, if the same are available for e-service.
/s/ Jason Charles Ciarochi
Jason Charles Ciarochi
UNOPPOSED MOTION TO WITHDRAW 3
Document Filed Date
June 13, 2019
Case Filing Date
May 02, 2019
Category
CNTR CNSMR COM DEBT
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FILED DALLAS COUNTY 6/1 3/2019 1:34 PM FELICIA PITRE D'STR'CT CLERK CAUSE N0. DC-19-06208 Terri Kilgore YOLANDA ALLEN § IN THE DISTRICT COURT § Plaintiff, § § § V. § 160th JUDICIAL DISTRICT § SAMI HABASH and § CHRISTINE SAHOURY § § § § § § § Defendants. § DALLAS COUNTY, TEXAS UNOPPOSED MOTION TO WITHDRAW COMES NOW, Yolanda M. Allen, Plaintiff in the above styled and referenced cause, and Ciarochi Law Firm, PLLC and files this Unopposed Motion t0 Withdraw and respectfully shows this Court as follows: I. Basis for Motion Plaintiff and her attorney have discussed this matter and have made the decision that the client’s interests are best served if an order of withdrawal is entered. This motion is unopposed — both Yolanda Allen (see attached letter) and Counsel for Defendants have indicated that they d0 not oppose this motion. There is not discovery between the parties that has a current response due date. II. Updated Contact Information for Yolanda Yolanda Allen presently has the following contact information: UNOPPOSED MOTION TO WITHDRAW 1 Yolanda Allen 1623 S. Westmoreland Glenn Heights, TX 75 1 54 (469) 337-3624 ymallen24@gmail.com III. Conclusion/Request for Relief Plaintiff Yolanda Allen and Ciarochi Law Firm PLLC request that this Court enter an order granting the withdrawal 0f Ciarochi Law Firm PLLC from representation in this case and that the Court take note 0f the contact information for Yolanda Allen for future notices. Respectfully submitted, /s/ Jason Charles Ciarochi Jason Charles Ciarochi State Bar No. 24012424 Ciarochi Law Firm, PLLC P.O. Box 29256 Dallas, Texas 75229 Phone: 214-642-2424 Fax: 2 14-242-2791 jason@ciarochilaw.com ATTORNEY FOR PLAINTIFF YOLANDA ALLEN CERTIFICATE OF CONFERENCE Plaintiff and Ciarochi Law Firm PLLC have discussed this Motion and are in agreement that the motion should be filed and hope that the Court Will enter an order 0f withdrawal. Defendants’ Counsel is aware of the Motion (has been emailed a copy 0f the motion) and has indicated that Defendants do not oppose the motion. UNOPPOSED MOTION TO WITHDRAW 2 /s/ Jason Charles Ciarochi Jason Charles Ciarochi CERTIFICATE OF SERVICE A copy 0f this filing has been sent t0 all parties in accordance with the Texas Rules of Civil Procedure on the date it was filed, if the same are available for e-service. /s/ Jason Charles Ciarochi Jason Charles Ciarochi UNOPPOSED MOTION TO WITHDRAW 3