No Value: WELLS FARGO BANK vs. UNITED STATES OF AMERICA ACTING THROUGH SECRETARY OF VETERANS AFFAIRS

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                                Filing # 186883381 E-Filed 11/28/2023 01:02:06 PM


                      IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
                              IN AND FOR OSCEOLA COUNTY, FLORIDA

        WELLS FARGO BANK, N.A,                                     Case No.: 2023 CA 003228 MF

               Plaintiff,

        vs.

        RAMON CARTAGENA; ET AL.

              Defendant(s).
        ______________________________________/

                                 MOTION FOR LEAVE TO WITHDRAW

                COMES NOW, the undersigned Counsel, Ayana Cruz and the Vanstone Law Firm,
        attorney for Defendants, Ramon Cartagena and Unknown Party #1 N/K/A Tommy Cartagena in
        the above styled cause, and moves this Court for permission to withdraw as attorney of record for
        the client and would state as follows:

               1. An impasse has been reached in the handling of the case, making it impossible for the
                  client and attorney to work cooperatively on the case.
               2. The clients have signed a Stipulation to Withdraw, which is attached to this Motion as
                  Exhibit “A.”
               3. The clients will not be prejudiced if the undersigned is permitted to withdraw.
               4. The clients can receive all further pleadings and correspondence at the following
                  address:

               Ramon Cartagena and Tommy Cartagena
               2581 Isabela Terrace
               Kissimmee, FL 34743
               tommyporras@gmail.com
               (321) 443-8120


                                       CERTIFICATE OF SERVICE

               I certify that a copy of this document was electronically served via the Florida Courts E-
        Filing Portal to Justin Ritchie, Albertelli Law, servealaw@albertellilaw.com and Ramon
        Cartagena and Tommy Cartagena, tommyporras@gmail.com, and via U.S. Mail, 2581 Isabela
        Terrace, Kissimmee, FL 34743 this 28th day of November, 2023.
Respectfully submitted,

By: /s/ Ayana Cruz
    AYANA CRUZ, Esquire
    Florida Bar No.: 39096
    VANSTONE LAW FIRM, LLC
    2100 Constitution Blvd., Suite 116
    Sarasota, Florida 34231
    Tel.: (941) 621-6220
    Fax: (941) 217-8291
    acruz@vanstonelaw.com
                                        EXHIBIT “A”

              STIPULATION FOR WITHDRAWAL OF COUNSEL

       Pursuant to the terms of the Representation Agreement dated

I/We Ramon           Cartagena        Tommy           Cartagena        hereby agree to authorize,

Alyssa A. Vanstone, Esquire and Vanstone Law Firm, LLC to file this Stipulation for

Withdrawal of Counsel at anytime in our case filed with the Osceola County         Judicial Circuit,

Case No.2023-CA-003228        and further, hereby authorize my/our attorney, Alyssa A. Vanstone,

Esquire and Vanstone Law Firm, LLC to take such action as is necessary to immediately and

formally withdraw appearance from said case and to be relieved as Counsel. We understand that

all further documents shall be sent to us and that we will be responsible for the representation of

my/our interests in said case henceforward.



_________________________________
Ramon         Cartagena                               ______________________________
                                                      Tommy          Cartagena
Print Name                           Date             Print Name                Date


_________________________________
                        06 / 13 / 2023                                       06 / 13 / 2023
                                                      ______________________________
Signature                                             Signature




                                                               Doc ID: 5f23803edf476b0022c6922024a59cfdc2a694c6