No Value: DINKINS-ANDERSON, VANSIA vs. DEXTER, VICTOR ANTHONY

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                                Filing # 180840350 E-Filed 08/30/2023 03:22:56 PM


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

        VANSIA DINKINS-ANDERSON                                     CASE NO.: 2021-CA-002312

               Plaintiff,

        v.

        VICTOR ANTHONY DEXTER,
        individually and derivatively on
        behalf of VENOM MOTOR
        SPORTS, LLC,

               Defendants.

        ______________________________/

                                           MOTION TO WITHDRAW

               NeJame Law, P.A., by the undersigned counsel, pursuant to all applicable rules of Florida

        Rules of Civil Procedure, hereby requests that this Court grant permission to withdraw as attorney

        of record and would state as follows:

               1.      NeJame Law, P.A. is currently serving as counsel to the Defendant, VICTOR

        ANTHONY DEXTER, individually and derivatively on behalf of VENOM MOTOR SPORTS,

        LLC.

               2.      The undersigned is unable, despite numerous attempts using various means, to

        communicate with Defendant, VICTOR ANTHONY DEXTER, individually and derivatively on

        behalf of VENOM MOTOR SPORTS, LLC., such that the undersigned can no longer effectively

        represent them. This case is still pending and the period for discovery did not conclude such that

        there is no prejudice to nor material adverse effect upon VICTOR ANTHONY DEXTER,

        individually and derivatively on behalf of VENOM MOTOR SPORTS, LLC., in the granting of

        this motion.



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       3.      Defendant’s last known mailing address is VICTOR ANTHONY DEXTER, 14112

Lord Barclay Drive, Orlando, FL 32837 and email address is venomd247@gmail.com.

       4.      A copy of this motion is being served on VICTOR ANTHONY DEXTER at his

last known mailing address and email address.

       5       Counsel for Defendant requests that the Defendant have 30 days from the date of

the order granting withdrawal of counsel in which to retain new counsel.

       WHEREFORE, the undersigned respectfully requests this Court enter its Order allowing

counsel to withdraw and any further relief as this Court may deem just.

       DATED this 30th day of August 2023.


                                                              /s/ Richard W. Smith______
                                                              Richard W. Smith, Esq.
                                                              Florida Bar No.: 13943
                                              `               NeJame Law, P.A.
                                                              189 S. Orange Ave., Ste. 1800
                                                              Orlando, FL 32801
                                                              Tele: 407-500-0000
                                                              Email: richard@nejamelaw.com
                                                              Email: laurie@nejamelaw.com
                                                              Email: civilservice@nejamelaw.com



                                     CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed on August

30, 2023, using the Court’s ePortal filing system which will send an electronic copy of the foregoing

pleading to all counsel of record.


                                                              /s/ Richard W. Smith______
                                                              Richard W. Smith, Esq.
                                                              Florida Bar No.: 13943


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