On May 05, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
and
for CONTRACT
in the District Court of Leon County.
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Filing # 177158374 E-Filed 07/11/2023 02:54:06 PM
IN THE CIRCUIT COURT OF THE
SECOND JUDICIAL CIRCUIT, IN AND
FOR LEON COUNTY, FLORIDA
CYPRESS RESTORATION, INC.,
A Florida corporation, d/b/a Paul
Davis Restoration of Tallahassee,
CIVIL DIVISION
Plaintiff, CASE NO.: 2022-CA-000752
VS.
BEVERLY A. WOODSON,
Defendant.
/
MOTION TO WITHDRAW AS COUNSEL OF
RECORD FOR DEFENDANT BEVERLY A. WOODSON
COMES NOW the undersigned attorneys of record for Defendant, BEVERLY A.
WOODSON, pursuant to Rule 2.505, Fla. R. Gen. Prac. & Jud. Admin, hereby files this Motion
to Withdraw as Counsel of Record and as grounds therefore states the following:
1 The undersigned has represented Defendant in this matter since entering an appearance
on July 13, 2022.
The matter was mediated on September 8, 2022, wherein an informed voluntary
settlement agreement was reached between the parties.
Defendant failed to satisfy the terms and conditions of the settlement agreement
prompting Plaintiff to file a subsequent Motion to Enforce Mediated Settlement
Agreement on October 10, 2022.
Despite repeated attempts to contact Defendant via telephone, text messages, email,
certified mail, and regular U.S. Mail, Defendant has not responded to any
communications from the undersigned since February 24, 2023.
5. Defendant’s last known contact information is:
Beverly Woodson
1054 High Meadows Drive
Tallahassee, Florida 32311
(850) 631-1705
Bawoodson3 | @gmail.com
6. The Court has now scheduled a Case Management Conference to take place at 3:30PM.
(EST) on September 7, 2023. Defendant has been informed of such Case Management
Conference but has not responded to the undersigned latest attempts for contact and
discussion.
Defendant’s lack of cooperation with the undersigned has prohibits the undersigned
continued representation in this matter such that the undersigned now seeks to formally
withdraw as Defendant’s counsel of record.
WHEREFORE, the undersigned attorneys hereby request the Court grant this Motion to
Withdraw as Counsel of Record and provide additional relief as this Court deems appropriate.
Respectfully submitted this 11th day of July, 2023.
kb
idee,
STUART C. POAGE, ESQUIRE
Florida Bar Number: 388246
RACHEL GIVENS, ESQUIRE
Florida Bar Number 1024797
PENNINGTON, P.A.
215 South Monroe Street, Suite 200
Tallahassee, Florida 32301
Telephone: (850) 222-3533
Facsimile: (850) 222-2126
spoage@penningtonlaw.com
givens@penningtonlaw.com
jduquetoro@penningtonlaw.com
Attorneys for Defendant
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed
electronically on July 11, 2023, with the Clerk of Court and sent via the court’s e-service system
to:
John W. Black, Esq.
2155 Delta Blvd., Suite 210-A
Tallahassee, Florida 32303
iwblack@nettally.com
jwhlack2155@outlook.com
Attorney for Plaintiff
Beverly Woodson
1054 High Meadows Drive
Tallahassee, Florida 32311
Bawoodson3 ](@gmail.com
Ree
Attorney
Document Filed Date
July 11, 2023
Case Filing Date
May 05, 2022
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Filing # 177158374 E-Filed 07/11/2023 02:54:06 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR LEON COUNTY, FLORIDA CYPRESS RESTORATION, INC., A Florida corporation, d/b/a Paul Davis Restoration of Tallahassee, CIVIL DIVISION Plaintiff, CASE NO.: 2022-CA-000752 VS. BEVERLY A. WOODSON, Defendant. / MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR DEFENDANT BEVERLY A. WOODSON COMES NOW the undersigned attorneys of record for Defendant, BEVERLY A. WOODSON, pursuant to Rule 2.505, Fla. R. Gen. Prac. & Jud. Admin, hereby files this Motion to Withdraw as Counsel of Record and as grounds therefore states the following: 1 The undersigned has represented Defendant in this matter since entering an appearance on July 13, 2022. The matter was mediated on September 8, 2022, wherein an informed voluntary settlement agreement was reached between the parties. Defendant failed to satisfy the terms and conditions of the settlement agreement prompting Plaintiff to file a subsequent Motion to Enforce Mediated Settlement Agreement on October 10, 2022. Despite repeated attempts to contact Defendant via telephone, text messages, email, certified mail, and regular U.S. Mail, Defendant has not responded to any communications from the undersigned since February 24, 2023. 5. Defendant’s last known contact information is: Beverly Woodson 1054 High Meadows Drive Tallahassee, Florida 32311 (850) 631-1705 Bawoodson3 | @gmail.com 6. The Court has now scheduled a Case Management Conference to take place at 3:30PM. (EST) on September 7, 2023. Defendant has been informed of such Case Management Conference but has not responded to the undersigned latest attempts for contact and discussion. Defendant’s lack of cooperation with the undersigned has prohibits the undersigned continued representation in this matter such that the undersigned now seeks to formally withdraw as Defendant’s counsel of record. WHEREFORE, the undersigned attorneys hereby request the Court grant this Motion to Withdraw as Counsel of Record and provide additional relief as this Court deems appropriate. Respectfully submitted this 11th day of July, 2023. kb idee, STUART C. POAGE, ESQUIRE Florida Bar Number: 388246 RACHEL GIVENS, ESQUIRE Florida Bar Number 1024797 PENNINGTON, P.A. 215 South Monroe Street, Suite 200 Tallahassee, Florida 32301 Telephone: (850) 222-3533 Facsimile: (850) 222-2126 spoage@penningtonlaw.com givens@penningtonlaw.com jduquetoro@penningtonlaw.com Attorneys for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed electronically on July 11, 2023, with the Clerk of Court and sent via the court’s e-service system to: John W. Black, Esq. 2155 Delta Blvd., Suite 210-A Tallahassee, Florida 32303 iwblack@nettally.com jwhlack2155@outlook.com Attorney for Plaintiff Beverly Woodson 1054 High Meadows Drive Tallahassee, Florida 32311 Bawoodson3 ](@gmail.com Ree Attorney