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NO. 2014-41901
DORA LINDA RODRIGUEZ AND IN THE DISTRICT COURT
FRANCISCO RODRIGUEZ
Plaintiffs
VS. HARRIS COUNTY, TEXAS
OVATION SERVICES, LLC
Defendant 333RD JUDICIAL DISTRICT
ROR MD Or EN nn a En
MOTION TO WITHDRAW AS COUNSEL
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES THEODORE HAYNES, JR., Attorney of Record for Plaintiffs/Counter-
Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ, Plaintiffs/Counter-
Defendants in the above entitled and numbered cause, and moves this honorable Court for
permission to withdraw as counsel of record for said Plaintiffs/Counter-Defendants, and as grounds
thereof would respectfully show unto the Court as follows:
&
1.01 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO
RODRIQUEZ, have discharged Attomey of Record, THEODORE HAYNES, JR., by a letter
received from Plaintiffs/Counter-Defendants to Attorney of Record for Plaintiffs/Counter-
Defendants, received on MAY 10, 2016, announcing, “Termination of Services.”1.02 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO
RODRIGUEZ and Attorney of Record, THEODORE HAYNES, JR., knowingly and freely assent
to the termination of his employment.
4.03 A copy of this motion has been delivered to Plaintiffs/Counter-Defendants, DORA
LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ.
1.04 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO
RODRIGUEZ have been notified in writing of their right to object to this motion.
1.05 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO
RODRIGUEZ’S' last known address is 19110 REMINGTON MILLS DRIVE, HOUSTON,
TEXAS 77073.
1.06 The pending settings and deadlines are as follows: FRIDAY, APRIL 13, 2016,
DEADLINE TO RESPOND TO DEFENDANT/COUNTER-PLAINTIFF OVATION
SERVICES’ REPLY, DEFENDANT/COUNTER-PLAINTIFF OVATION SERVICES’
OBJECTION TO MEDIATION AND PLAINTIFFS/COUNTER-DEFENDANTS’ RESPONSE
TO OBJECTION TO MEDIATION REMAIN UNLITIGATED, FRIDAY, MAY 27, 2016,
STATUS CONFERENCE, MONDAY, AUGUST 8, 2016, JURY TRIAL ON THE MERITS.1.07 WITHDRAWAL WILL HAVE A MATERIAL AND ADVERSE EFFECT ON
PLAINTIFFS/COUNTER-DEFENDANTS DORA LINDA RODRIGUEZ and FRANCISICO
RODRIGUEZ, DEPENDING ON WHAT THE COURT RULES. THERE ARE ADDITIONAL
SUMMARY JUDGMENT EVIDENCE AND SUMMARY JUDGMENT AFFIDAVITS, WHICH
ARE OUTCOME DETERMINATIVE, AND CAN BE PRESENTED BY
PLAINTIFFS/COUNTER-DEFENDANTS, BUT REQUIRE THE COOPERATION OF THE
PLAINTIFFS/COUNTER-DEFENDANTS AND THE AUTHORITY OF THE ATTORNEY OF
RECORD FOR THE PLAINTIFFS/COUNTER-DEFENDANTS TO FILE AND LITIGATE
SUCH EVIDENCE, NEITHER OF WHICH EXISTS AT THIS TIME.
WHEREFORE, premises considered, Attorney of Record for Plaintiffs/Counter-Defendants,
THEODORE HAYNES, JR., prays the Court to grant him permission to withdraw as counsel of
record for Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO
RODRIGUEZ.
Respectfully submitted,
Aor
THEODORE HAYNES, JR.
Attorney for Plaintiffs/Counter-Defendants
DORA LINDA RODRIGUES and
FRANCISCO RODRIGUEZ
Texas Bar No. 00787665
P.O. BOX 300833
HOUSTON, TEXAS 77230-0833
Telephone: (713) 249-1159
Telecopier: (832) 328-5111
E-mail: thaynesjr@prodigy.netCERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above Motion to Withdraw as Counsel
has been sent by e-mail, hand delivery, facsimile and certified mail by depositing it enclosed in a
postpaid, properly addressed wrapper in a post office or official depository under the care and
custody of the United States Postal Service to Mr. Michael J. Dority, 1010 Lamar Street, Suite 425,
Houston, Texas 77002, Attorney of Record for Defendant, Ovation Services, L.L..C.
SIGNED this L974 day or M44. 201%.
¢
Theodore Haynes, Jr.
Attorney for Plaintiffs/Counter-Defendants
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NO. 2014-41901 DORA LINDA RODRIGUEZ AND IN THE DISTRICT COURT FRANCISCO RODRIGUEZ Plaintiffs VS. HARRIS COUNTY, TEXAS OVATION SERVICES, LLC Defendant 333RD JUDICIAL DISTRICT ROR MD Or EN nn a En MOTION TO WITHDRAW AS COUNSEL TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES THEODORE HAYNES, JR., Attorney of Record for Plaintiffs/Counter- Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ, Plaintiffs/Counter- Defendants in the above entitled and numbered cause, and moves this honorable Court for permission to withdraw as counsel of record for said Plaintiffs/Counter-Defendants, and as grounds thereof would respectfully show unto the Court as follows: & 1.01 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIQUEZ, have discharged Attomey of Record, THEODORE HAYNES, JR., by a letter received from Plaintiffs/Counter-Defendants to Attorney of Record for Plaintiffs/Counter- Defendants, received on MAY 10, 2016, announcing, “Termination of Services.”1.02 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ and Attorney of Record, THEODORE HAYNES, JR., knowingly and freely assent to the termination of his employment. 4.03 A copy of this motion has been delivered to Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ. 1.04 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ have been notified in writing of their right to object to this motion. 1.05 Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ’S' last known address is 19110 REMINGTON MILLS DRIVE, HOUSTON, TEXAS 77073. 1.06 The pending settings and deadlines are as follows: FRIDAY, APRIL 13, 2016, DEADLINE TO RESPOND TO DEFENDANT/COUNTER-PLAINTIFF OVATION SERVICES’ REPLY, DEFENDANT/COUNTER-PLAINTIFF OVATION SERVICES’ OBJECTION TO MEDIATION AND PLAINTIFFS/COUNTER-DEFENDANTS’ RESPONSE TO OBJECTION TO MEDIATION REMAIN UNLITIGATED, FRIDAY, MAY 27, 2016, STATUS CONFERENCE, MONDAY, AUGUST 8, 2016, JURY TRIAL ON THE MERITS.1.07 WITHDRAWAL WILL HAVE A MATERIAL AND ADVERSE EFFECT ON PLAINTIFFS/COUNTER-DEFENDANTS DORA LINDA RODRIGUEZ and FRANCISICO RODRIGUEZ, DEPENDING ON WHAT THE COURT RULES. THERE ARE ADDITIONAL SUMMARY JUDGMENT EVIDENCE AND SUMMARY JUDGMENT AFFIDAVITS, WHICH ARE OUTCOME DETERMINATIVE, AND CAN BE PRESENTED BY PLAINTIFFS/COUNTER-DEFENDANTS, BUT REQUIRE THE COOPERATION OF THE PLAINTIFFS/COUNTER-DEFENDANTS AND THE AUTHORITY OF THE ATTORNEY OF RECORD FOR THE PLAINTIFFS/COUNTER-DEFENDANTS TO FILE AND LITIGATE SUCH EVIDENCE, NEITHER OF WHICH EXISTS AT THIS TIME. WHEREFORE, premises considered, Attorney of Record for Plaintiffs/Counter-Defendants, THEODORE HAYNES, JR., prays the Court to grant him permission to withdraw as counsel of record for Plaintiffs/Counter-Defendants, DORA LINDA RODRIGUEZ and FRANCISCO RODRIGUEZ. Respectfully submitted, Aor THEODORE HAYNES, JR. Attorney for Plaintiffs/Counter-Defendants DORA LINDA RODRIGUES and FRANCISCO RODRIGUEZ Texas Bar No. 00787665 P.O. BOX 300833 HOUSTON, TEXAS 77230-0833 Telephone: (713) 249-1159 Telecopier: (832) 328-5111 E-mail: thaynesjr@prodigy.netCERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above Motion to Withdraw as Counsel has been sent by e-mail, hand delivery, facsimile and certified mail by depositing it enclosed in a postpaid, properly addressed wrapper in a post office or official depository under the care and custody of the United States Postal Service to Mr. Michael J. Dority, 1010 Lamar Street, Suite 425, Houston, Texas 77002, Attorney of Record for Defendant, Ovation Services, L.L..C. SIGNED this L974 day or M44. 201%. ¢ Theodore Haynes, Jr. Attorney for Plaintiffs/Counter-Defendants