On August 11, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Geico County Mutual Insurance Company,
and
Arukwe, Nkechinyere,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
11/7/2023 11:32 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Lauren Beavers DEPUTY
N0. DC-22-09627
§
GEICO COUNTY MUTUAL §
INSURANCE COMPANY, § IN THE DISTRICT COURT 44TH
§ JUDICIAL DISTRICT
Plaintiff, §
§
§ DALLAS COUNTY, TEXAS
NKECHINYERE ARUKWE, §
§
Defendant. §
MOTION FOR WITHDRAW OF COUNSEL
TO THE HONORABLE JUDGE OF SAID COURT:
This Motion for Withdrawal of Counsel is brought by Movant, Ervin “Bill” Layer (“BILL
LAYER”) of Borell Law, P.A. BILL LAYER requests the Court to grant permission to withdraw
B]LL LAYER and Borell Law, P.A. as attorneys of record for NKECHINYERE ARUKWE in
this case. In support, BILL LAYER shows:
1. Good cause exists for withdrawal of Movant as counsel. NKECHlNYERE ARUKWE
have not abided by the terms of their Retainer Agreement and/or Contract Agreement
with Borell Law, P.A.
2. NKECHINYERE ARUKWE was given a ten-day notice (see Exhibit A) to reconcile
their Retainer Agreement and/or Contract Agreement with Borell Law, P.A. and has
failed to do so.
3. The parties of the above-entitled case have yet to exchange initial disclosures and BILL
LAYER is not in receipt of any other discovery requests.
4. The above-entitled case has no pending settings to date of this motion.
This Motion is not sought for the purposes of delay.
Movant requests that all notices in this case be delivered to NKECHINYERE ARUKWE
in person or sent to NKECHINYERE ARUKWE’S last known address at 13704 Biggs Street
MOTION To WITHDRAW 0F COUNSEL PAGE 1 OF 3
ARUKWE, NKECHINYERE, CAUSE NO.: DC2209627
Dallas, TX 75253. NKECHINYERE ARUKWE has a right to object to this Motion. A
copy of this motion and the attachments will be delivered to the last known address of
NKECHINYERE ARUKWE. BILL LAYER prays that the Court enter an order discharging
BILL LAYER and Borell Law, P.A. as attorneys of record for NKECHINYERE ARUKWE.
Respectfully submitted,
Borell Law, P.A.,
/S/ {Bram
Ervin “Bill” Layer
Texas Bar No. 24094790
8300 Douglas Ave, Suite 800
Dallas, TX 75225
Tel. 305-514-0500
Fax 305-357-9233
service@borell.com
blayer@borell.com
MOTION To WITHDRAW 0F COUNSEL PAGE 2 OF 3
ARUKWE, NKECHINYERE, CAUSE No.: DC2209627
CERTIFICATE OF SERVICE
I certify that on October 26, 2023, a true and correct copy of the foregoing document was
served in accordance with the Texas Rules of Civil Procedure.
Via e-filing service:
STEIL & ASSOCIATES
SHARIS HAUDER
2280 North GreenVille Avenue,
Richardson, Texas 75082-4412
Telephone: 972-855-6400
Email: shauder@geico.com
Attorneys for Defendant
Via First Class Mail and CMRRR:
Nkechinyere Arukwe
13704 Biggs street
Dallas, TX 75253
nkemhe255@yahoo.com
/s/ {Bill Bayes
ErVin “Bill” Layer
MOTION To WITHDRAW 0F COUNSEL PAGE 3 OF 3
ARUKWE, NKECHINYERE, CAUSE No.: DC2209627
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.
Service for The Law Offices of Alexander E. Borell P.A. on behalf of Ervin
"Bill" Layer
Bar No. 24094790
service@borell.com
Envelope ID: 81380245
Filing Code Description: Motion - Withdraw Attorney
Filing Description:
Status as of 11/8/2023 8:19 AM CST
Associated Case Party: GEICO COUNTY MUTUAL INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted Status
GIGI MATTTAR efiletx@ezmessenger.com 11/7/2023 11:32:46 AM SENT
Gigi Mattar GMattar@Rathbonegroup.com 11/7/2023 11:32:46 AM SENT
Sharis Hauder shauder@geico.com 11/7/2023 11:32:46 AM SENT
Michelle Lopez michelopez@geico.com 11/7/2023 11:32:46 AM SENT
Associated Case Party: NKECHINYERE ARUKWE
Name BarNumber Email TimestampSubmitted Status
Katie Contreras kcontreras@borell.com 11/7/2023 11:32:46 AM SENT
Donald W.Dickson service@borell.com 11/7/2023 11:32:46 AM SENT
Ervin Layer blayer@borell.com 11/7/2023 11:32:46 AM SENT
Service for The Law Offices of Alexander E. Borell, P.A. service@borell.com 11/7/2023 11:32:46 AM SENT
Document Filed Date
November 07, 2023
Case Filing Date
August 11, 2022
Category
CNTR CNSMR COM DEBT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 11/7/2023 11:32 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Lauren Beavers DEPUTY N0. DC-22-09627 § GEICO COUNTY MUTUAL § INSURANCE COMPANY, § IN THE DISTRICT COURT 44TH § JUDICIAL DISTRICT Plaintiff, § § § DALLAS COUNTY, TEXAS NKECHINYERE ARUKWE, § § Defendant. § MOTION FOR WITHDRAW OF COUNSEL TO THE HONORABLE JUDGE OF SAID COURT: This Motion for Withdrawal of Counsel is brought by Movant, Ervin “Bill” Layer (“BILL LAYER”) of Borell Law, P.A. BILL LAYER requests the Court to grant permission to withdraw B]LL LAYER and Borell Law, P.A. as attorneys of record for NKECHINYERE ARUKWE in this case. In support, BILL LAYER shows: 1. Good cause exists for withdrawal of Movant as counsel. NKECHlNYERE ARUKWE have not abided by the terms of their Retainer Agreement and/or Contract Agreement with Borell Law, P.A. 2. NKECHINYERE ARUKWE was given a ten-day notice (see Exhibit A) to reconcile their Retainer Agreement and/or Contract Agreement with Borell Law, P.A. and has failed to do so. 3. The parties of the above-entitled case have yet to exchange initial disclosures and BILL LAYER is not in receipt of any other discovery requests. 4. The above-entitled case has no pending settings to date of this motion. This Motion is not sought for the purposes of delay. Movant requests that all notices in this case be delivered to NKECHINYERE ARUKWE in person or sent to NKECHINYERE ARUKWE’S last known address at 13704 Biggs Street MOTION To WITHDRAW 0F COUNSEL PAGE 1 OF 3 ARUKWE, NKECHINYERE, CAUSE NO.: DC2209627 Dallas, TX 75253. NKECHINYERE ARUKWE has a right to object to this Motion. A copy of this motion and the attachments will be delivered to the last known address of NKECHINYERE ARUKWE. BILL LAYER prays that the Court enter an order discharging BILL LAYER and Borell Law, P.A. as attorneys of record for NKECHINYERE ARUKWE. Respectfully submitted, Borell Law, P.A., /S/ {Bram Ervin “Bill” Layer Texas Bar No. 24094790 8300 Douglas Ave, Suite 800 Dallas, TX 75225 Tel. 305-514-0500 Fax 305-357-9233 service@borell.com blayer@borell.com MOTION To WITHDRAW 0F COUNSEL PAGE 2 OF 3 ARUKWE, NKECHINYERE, CAUSE No.: DC2209627 CERTIFICATE OF SERVICE I certify that on October 26, 2023, a true and correct copy of the foregoing document was served in accordance with the Texas Rules of Civil Procedure. Via e-filing service: STEIL & ASSOCIATES SHARIS HAUDER 2280 North GreenVille Avenue, Richardson, Texas 75082-4412 Telephone: 972-855-6400 Email: shauder@geico.com Attorneys for Defendant Via First Class Mail and CMRRR: Nkechinyere Arukwe 13704 Biggs street Dallas, TX 75253 nkemhe255@yahoo.com /s/ {Bill Bayes ErVin “Bill” Layer MOTION To WITHDRAW 0F COUNSEL PAGE 3 OF 3 ARUKWE, NKECHINYERE, CAUSE No.: DC2209627 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. Service for The Law Offices of Alexander E. Borell P.A. on behalf of Ervin "Bill" Layer Bar No. 24094790 service@borell.com Envelope ID: 81380245 Filing Code Description: Motion - Withdraw Attorney Filing Description: Status as of 11/8/2023 8:19 AM CST Associated Case Party: GEICO COUNTY MUTUAL INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status GIGI MATTTAR efiletx@ezmessenger.com 11/7/2023 11:32:46 AM SENT Gigi Mattar GMattar@Rathbonegroup.com 11/7/2023 11:32:46 AM SENT Sharis Hauder shauder@geico.com 11/7/2023 11:32:46 AM SENT Michelle Lopez michelopez@geico.com 11/7/2023 11:32:46 AM SENT Associated Case Party: NKECHINYERE ARUKWE Name BarNumber Email TimestampSubmitted Status Katie Contreras kcontreras@borell.com 11/7/2023 11:32:46 AM SENT Donald W.Dickson service@borell.com 11/7/2023 11:32:46 AM SENT Ervin Layer blayer@borell.com 11/7/2023 11:32:46 AM SENT Service for The Law Offices of Alexander E. Borell, P.A. service@borell.com 11/7/2023 11:32:46 AM SENT