On November 01, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
State Of Texas,
and
Cotton, Alvin Desean,
for FELONY-1
in the District Court of Dallas County.
Preview
FILED
12/12/2023 7:05 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Felicia Pitre DEPUTY
Cause No. F2377156
STATE OF TEXAS § IN THE 195TH DISTRICT
§
V. § COURT OF
§
ALVIN COTTON § DALLAS COUNTY
TEXAS
MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANT
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Movant, TYLER CARLETON, (hereafter Movant) Attorney of Record for
the Defendant, ALVIN COTTON, (hereafter Defendant) in the above styled and numbered
cause, who would file this Motion to withdraw as counsel in the present cause, and would show
unto the Court as follows:
I.
Movant is unable to communicate effectively with Client/Defendant ALVIN COTTON to
the point that the purpose of the representation of the Defendant are irreparably frustrated.
Communication between an attorney and their client is paramount for effective representation to
occur. Accordingly, the aforementioned considerations have greatly reduced the ability of
present counsel to provide adequate representation to the Defendant and has ultimately rendered
an ongoing attorney/client relationship impossible. Further, Defendant has failed to make
timely payments towards legal fees due to Movant.
II.
Movant is unaware if Defendant consents to this motion to withdraw. Movant has made
Defendant aware that Movant will be filing a motion to withdraw in this case as set out below in
the Certificate of Service. The Defendant is hereby notified in writing of his right to object to this
motion. Movant will serve Defendant, on or about the date this motion is filed, at Defendant’s
last known address via hand delivery at the Lew Sterrett jail in Dallas County Texas.
III.
This cause/allegation is currently set for an announcement in the 195th District Court of
Dallas County on December 14, 2023, at 8:00 a.m.
IV.
The granting of this Motion to Withdraw will not jeopardize the rights of the Defendant. The
requested withdrawal as counsel is not for the purposes of delay. Defendant has ample
opportunity to employ counsel, represent himself or request court appointed counsel. Movant
requests the Honorable Court, release Movant from representing Defendant ALVIN COTTON in
the cause described herein as well as any and all causes of any kind related or not, pending in
Dallas County Texas, if any, against ALVIN COTTON.
WHEREFORE, PREMISES CONSIDERED, Movant prays that this Honorable Court
allow the withdrawal of counsel, and that present counsel be released from further obligation or
duty to the Defendant ALVIN COTTON upon release from his status as Attorney of Record of
Defendant.
Respectfully submitted,
By: /s/Tyler Carleton
TCARLETON10@GMAIL.COM
State Bar No. 24076088
The Law Office of Tyler
Carleton
2626 Cole Avenue Suite 300
Dallas, Texas 75204
Phone: 214 649 4605
Fax: 1 972 692 8749
ATTORNEY FOR DEFENDANT
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the foregoing Motion to
Withdraw was forwarded to the Dallas County District Attorney or a rightful agent thereof via e-
file/e-mail on or about the date this document is file marked.
I, the undersigned, hereby certify that a true and correct physical copy of the foregoing
Motion to Withdraw was hand delivered to the Defendant in the Lew Sterrett Jail in Dallas
County Texas on or about the time the motion was drafted.
Respectfully submitted,
By: /S/Tyler Carleton
TYLER CARLETON
State Bar No. 24076088
Attorney for Defendant
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.
Envelope ID: 82510235
Filing Code Description: MOTIONS - WITHDRAW ATTORNEY
Filing Description: MOTION - WITHDRAW AS COUNSEL
Status as of 12/15/2023 1:29 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Joel Abraham Joel.Abraham@Dallascounty.org 12/12/2023 7:05:42 PM SENT
Document Filed Date
December 12, 2023
Case Filing Date
November 01, 2023
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 12/12/2023 7:05 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Felicia Pitre DEPUTY Cause No. F2377156 STATE OF TEXAS § IN THE 195TH DISTRICT § V. § COURT OF § ALVIN COTTON § DALLAS COUNTY TEXAS MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANT TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES Movant, TYLER CARLETON, (hereafter Movant) Attorney of Record for the Defendant, ALVIN COTTON, (hereafter Defendant) in the above styled and numbered cause, who would file this Motion to withdraw as counsel in the present cause, and would show unto the Court as follows: I. Movant is unable to communicate effectively with Client/Defendant ALVIN COTTON to the point that the purpose of the representation of the Defendant are irreparably frustrated. Communication between an attorney and their client is paramount for effective representation to occur. Accordingly, the aforementioned considerations have greatly reduced the ability of present counsel to provide adequate representation to the Defendant and has ultimately rendered an ongoing attorney/client relationship impossible. Further, Defendant has failed to make timely payments towards legal fees due to Movant. II. Movant is unaware if Defendant consents to this motion to withdraw. Movant has made Defendant aware that Movant will be filing a motion to withdraw in this case as set out below in the Certificate of Service. The Defendant is hereby notified in writing of his right to object to this motion. Movant will serve Defendant, on or about the date this motion is filed, at Defendant’s last known address via hand delivery at the Lew Sterrett jail in Dallas County Texas. III. This cause/allegation is currently set for an announcement in the 195th District Court of Dallas County on December 14, 2023, at 8:00 a.m. IV. The granting of this Motion to Withdraw will not jeopardize the rights of the Defendant. The requested withdrawal as counsel is not for the purposes of delay. Defendant has ample opportunity to employ counsel, represent himself or request court appointed counsel. Movant requests the Honorable Court, release Movant from representing Defendant ALVIN COTTON in the cause described herein as well as any and all causes of any kind related or not, pending in Dallas County Texas, if any, against ALVIN COTTON. WHEREFORE, PREMISES CONSIDERED, Movant prays that this Honorable Court allow the withdrawal of counsel, and that present counsel be released from further obligation or duty to the Defendant ALVIN COTTON upon release from his status as Attorney of Record of Defendant. Respectfully submitted, By: /s/Tyler Carleton TCARLETON10@GMAIL.COM State Bar No. 24076088 The Law Office of Tyler Carleton 2626 Cole Avenue Suite 300 Dallas, Texas 75204 Phone: 214 649 4605 Fax: 1 972 692 8749 ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE I, the undersigned, hereby certify that a true and correct copy of the foregoing Motion to Withdraw was forwarded to the Dallas County District Attorney or a rightful agent thereof via e- file/e-mail on or about the date this document is file marked. I, the undersigned, hereby certify that a true and correct physical copy of the foregoing Motion to Withdraw was hand delivered to the Defendant in the Lew Sterrett Jail in Dallas County Texas on or about the time the motion was drafted. Respectfully submitted, By: /S/Tyler Carleton TYLER CARLETON State Bar No. 24076088 Attorney for Defendant 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. Envelope ID: 82510235 Filing Code Description: MOTIONS - WITHDRAW ATTORNEY Filing Description: MOTION - WITHDRAW AS COUNSEL Status as of 12/15/2023 1:29 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Joel Abraham Joel.Abraham@Dallascounty.org 12/12/2023 7:05:42 PM SENT