On July 09, 2018 a
AGREED MOTION TO WITHDRAW - MOTION - WITHDRAW ATTORNEY
was filed
involving a dispute between
Merwin, Betty,
Merwin, Lee,
Rushing, Janice,
Rushing, Lige, Jr,
and
Merwin, Betty,
Merwin, Lee,
Rushing, Janice,
Rushing, Lige, Jr.,
for PROPERTY
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
11/8/2019 6:06PM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-18-08876 Cassandra Walker
LEE MERWIN and BETTY § IN THE DISTRICT COURT
MERWIN §
Plaintiffs, §
§
VS. § DALLAS COUNTY TEXAS
§
JANICE RUSHING and LIGE §
RUSHING, JR., §
Defendants. § 192ND JUDICIAL DISTRICT
AGREED MOTION TO WITHDRAW AS ATTORNEY OF RECORD
FOR JANICE AND LIGE RUSHING, JR.
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Robert A. Miller and the law firm 0f Prager & Miller, P.C.,
Movants, and moves this court for permission t0 Withdraw as Attorney 0f Record
for Janice Rushing and Lige Rushing, Jr. (“Defendants”) and in support thereof Will
hereby show this honorable court the following:
1. The Rushings requested that Mr. Miller not represent them by letter
dated October 29, 201 8 attached hereto as Exhibit A.
2. Robert Frisch, filed an entry 0f appearance 0n January 26, 2019 and is
currently the attorney in charge 0f the case.
3. Mr. Frisch has been acting as the only attorney in the case since he filed
his Notice 0f Appearance.
4. Withdrawal will not occasion undue delay in the disposition of this
MOTION TO WITHDRAW Page 1of 3
Merwin v.Rushing
(P&M PC Mot. To Withdraw - Page 1 of 4)
cause.
5. Counsel for Plaintiff does not oppose the Motion.
6. This Motion to Withdraw is not sought for delay only.
WHEREFORE, PREMISES CONSIDERED, Robert A. Miller and the law
firm of Prager & Miller, P.C. pray that their Motion t0 Withdraw as attorney of
record be granted and for such other further relief at law 0r in equity t0 which they
may show themselves justly entitled.
Respectfully submitted,
PRAGER & MILLER P.C.
By: /s/ Robert A. Miller
Robert A. Miller
State Bar N0. 14108200
14911 Quorum Drive, Suite 320
Dallas, Texas 75254
972-661-9211 - Telephone
972—661-9859 — Facsimile
rmiller@prager—miller.com
CERTIFICATE OF CONFERENCE
On October 31 on separate telephone calls with Darrell D. Minter, attorney
for Plaintiffs and Robert K. Frisch attorney for Defendants they were not opposed t0
this Motion.
/s/ Robert A. Miller
Robert A. Miller
MOTION TO VVITHDRAW Page 2 0f 3
Merwin v.Rushing
(P&M PC Mot. To Withdraw - Page 2 of 4)
CERTIFICATE OF SERVICE
I the undersigned hereby certify that a true and correct copy of the above and
foregoing document was served 0n the attorney(s) of record for the parties by a
method approved by the Texas Rules of Civil Procedure Rule 21a, 0n this 8th
Day of
November, 20 1 6.
Darrell D. Minter
Underwood Perkins, P.C.
Two Lincoln Centre
5420 LBJ Freeway, Suite 1900
Dallas, TX 75240
Fax No.: (972) 661-5691
Email: dminter@unlawtx.com
Robert K. Frisch
15150 Preston Rd., Suite 240
Dallas, TX 75248
Fax No. 972-764-0928
Email: rkfrischlangmsnxom
/s/ Robert A. Miller
ROBERT A. MILLER
MOTION TO VVITHDRAW Page 3 0f 3
Merwin v.Rushing
(P&M PC Mot. To Withdraw - Page 3 of 4)
Exhibit "A"
Tel 214-368-3611
Tel LlGE
LIGE B. B. RUSHING, JR, JR., M.D.,
M.D., M.S.,
M.S., P.A.
P.A. 214-6%-3695
FAX 214.696.3695
DWLOMA TE AMERICAN BOARD INTERNAL MEDICINE
DIPLOMATE
GERIATRICS & & RHEUMATOLOGY
8210 WALNUT HILL
82IOWALNUT IIILL LANE
SUITE 120
DALLAS, TX 75231
October 29,29,2018
201 8
Mr. Robert
Mr. Robert A. Miller
A. Miller
14911
14911 Quorum Dr. Dr.,, Suite
Suite 320
Dallas,
Dallas, TX 75254 —
- 1482
1482 HAND DELIVERED
Dear MLMiller,
Dear Mr.Miller,
This letter is
This letter is to inform you
to inform you that
that II am formally
formally terminating
terminating ourour attomey-client
attorney-client relationship.
relationship.
Yours truly,
_ 7
(P&M PC Mot. To Withdraw - Page 4 of 4)
Document Filed Date
November 08, 2019
Case Filing Date
July 09, 2018
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FILED DALLAS COUNTY 11/8/2019 6:06PM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-18-08876 Cassandra Walker LEE MERWIN and BETTY § IN THE DISTRICT COURT MERWIN § Plaintiffs, § § VS. § DALLAS COUNTY TEXAS § JANICE RUSHING and LIGE § RUSHING, JR., § Defendants. § 192ND JUDICIAL DISTRICT AGREED MOTION TO WITHDRAW AS ATTORNEY OF RECORD FOR JANICE AND LIGE RUSHING, JR. TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, Robert A. Miller and the law firm 0f Prager & Miller, P.C., Movants, and moves this court for permission t0 Withdraw as Attorney 0f Record for Janice Rushing and Lige Rushing, Jr. (“Defendants”) and in support thereof Will hereby show this honorable court the following: 1. The Rushings requested that Mr. Miller not represent them by letter dated October 29, 201 8 attached hereto as Exhibit A. 2. Robert Frisch, filed an entry 0f appearance 0n January 26, 2019 and is currently the attorney in charge 0f the case. 3. Mr. Frisch has been acting as the only attorney in the case since he filed his Notice 0f Appearance. 4. Withdrawal will not occasion undue delay in the disposition of this MOTION TO WITHDRAW Page 1of 3 Merwin v.Rushing (P&M PC Mot. To Withdraw - Page 1 of 4) cause. 5. Counsel for Plaintiff does not oppose the Motion. 6. This Motion to Withdraw is not sought for delay only. WHEREFORE, PREMISES CONSIDERED, Robert A. Miller and the law firm of Prager & Miller, P.C. pray that their Motion t0 Withdraw as attorney of record be granted and for such other further relief at law 0r in equity t0 which they may show themselves justly entitled. Respectfully submitted, PRAGER & MILLER P.C. By: /s/ Robert A. Miller Robert A. Miller State Bar N0. 14108200 14911 Quorum Drive, Suite 320 Dallas, Texas 75254 972-661-9211 - Telephone 972—661-9859 — Facsimile rmiller@prager—miller.com CERTIFICATE OF CONFERENCE On October 31 on separate telephone calls with Darrell D. Minter, attorney for Plaintiffs and Robert K. Frisch attorney for Defendants they were not opposed t0 this Motion. /s/ Robert A. Miller Robert A. Miller MOTION TO VVITHDRAW Page 2 0f 3 Merwin v.Rushing (P&M PC Mot. To Withdraw - Page 2 of 4) CERTIFICATE OF SERVICE I the undersigned hereby certify that a true and correct copy of the above and foregoing document was served 0n the attorney(s) of record for the parties by a method approved by the Texas Rules of Civil Procedure Rule 21a, 0n this 8th Day of November, 20 1 6. Darrell D. Minter Underwood Perkins, P.C. Two Lincoln Centre 5420 LBJ Freeway, Suite 1900 Dallas, TX 75240 Fax No.: (972) 661-5691 Email: dminter@unlawtx.com Robert K. Frisch 15150 Preston Rd., Suite 240 Dallas, TX 75248 Fax No. 972-764-0928 Email: rkfrischlangmsnxom /s/ Robert A. Miller ROBERT A. MILLER MOTION TO VVITHDRAW Page 3 0f 3 Merwin v.Rushing (P&M PC Mot. To Withdraw - Page 3 of 4) Exhibit "A" Tel 214-368-3611 Tel LlGE LIGE B. B. RUSHING, JR, JR., M.D., M.D., M.S., M.S., P.A. P.A. 214-6%-3695 FAX 214.696.3695 DWLOMA TE AMERICAN BOARD INTERNAL MEDICINE DIPLOMATE GERIATRICS & & RHEUMATOLOGY 8210 WALNUT HILL 82IOWALNUT IIILL LANE SUITE 120 DALLAS, TX 75231 October 29,29,2018 201 8 Mr. Robert Mr. Robert A. Miller A. Miller 14911 14911 Quorum Dr. Dr.,, Suite Suite 320 Dallas, Dallas, TX 75254 — - 1482 1482 HAND DELIVERED Dear MLMiller, Dear Mr.Miller, This letter is This letter is to inform you to inform you that that II am formally formally terminating terminating ourour attomey-client attorney-client relationship. relationship. Yours truly, _ 7 (P&M PC Mot. To Withdraw - Page 4 of 4)