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No. 2006-38382
KALETA JOHNSON AND IN THE DISTRICT COURT
SETH JOHNSON
Plaintiffs,
vs. OF HARRIS COUNTY, TEXAS
DINESH K. SHAH and
DAVID W. COLLIE,
Defendants.
MOAN UUW 107
295" JUDICIAL DISTRICT
FILED
TO THE HONORABLE JUDGE OF SAID COURT: Loren Jeger
MOTION TO WITHDRAW AS COUNSEL
Comes now, Peter M. Blute, attorney for Defendant, Dinesh K. Shah, S54 rbRi2Q08
permission, pursuant to Rule 10 of the Texas Rules of Civil Procedlfé, Came
representing Defendant, Dinesh K. Shah.
This motion is based on good cause in that an irreconcilable conflict has arisen
between the undersigned and his client, and it has become impractical for Peter M. Blute
to continue to represent Dinesh K. Shah. The withdrawal is not sought for delay, but
that justice may be done.
1. No other attorney has been retained by the client to substitute.
2. A copy of this motion, notice of hearing, and notice of right to object has been
delivered to the client, both by fax, certified mail posted, and regular mail on
December 12, 2008.
3. By copy of this Motion, the party has been advised of his right to object to the
motion, and to set a hearing on such motion.
5. The party has not given written consent to this motion.
6. Dinesh K. Shah has the following last known address:
1302 Waugh Dr. #221
Houston, Texas 77043
7. The following are settings and deadlines pending in this matter:
a. Discovery responses to discovery dated July 8, 2008 are due by Defendant,
Shah, no later than December 10, 2008. If there is any supplementation to
such discovery, it will be governed by the Texas Rules of Civil Procedure.b. Bond hearing is scheduled by the Court for December 19, 2008 at 9:00 a.m..
8. The client is advised that this motion has been set for oral hearing to the
Court on December 19, 2008, at 9:00 a.m. You have a right to contest this
motion.
WHEREFORE, PREMISES CONSIDERED, Peter M. Blute respectfully requests
that this Court sign the attached Order permitting him to withdraw from this cause and for
all further relief to which he may be justly entitled.
Respectfully submitted,
Gh 11 GA.
PETER M. BLUTE
SBN 02521600
7676 Hillmont, Suite 150
Houston, Texas 77040
Tel.: (713) 460-5500
Fax: (713) 460-2265
ATTORNEY FOR DEFENDANT
DINESH K. SHAH
CERTIFICATE OF SERVICE
This is to certify that the foregoing instrument was forwarded to all counsel of record
by certified mail, return receipt requested, or regular mail, hand delivery, or by facsimile
transmission to:
Paul D. Clote
Four Houston Center
1221 Lamar, Suite 1090
Houston, Texas 77010
Fax: (713) 654-0052
Jim M. Perdue, Jr.
Perdue & Kidd, L.L.P.
Wortham Tower
2727 Allen Parkway, Suite 800
Houston, Texas 77019
Fax: (713) 520-2525
Dinesh K. Shah
1302 Waugh Dr. #221
Houston, Texas 77043
VIA: fax transmission, regular mail and certified mailon this 12th day of December, 2008.
Jk 11 late
Peter M. Blute
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p3 No. 2006-38382 KALETA JOHNSON AND IN THE DISTRICT COURT SETH JOHNSON Plaintiffs, vs. OF HARRIS COUNTY, TEXAS DINESH K. SHAH and DAVID W. COLLIE, Defendants. MOAN UUW 107 295" JUDICIAL DISTRICT FILED TO THE HONORABLE JUDGE OF SAID COURT: Loren Jeger MOTION TO WITHDRAW AS COUNSEL Comes now, Peter M. Blute, attorney for Defendant, Dinesh K. Shah, S54 rbRi2Q08 permission, pursuant to Rule 10 of the Texas Rules of Civil Procedlfé, Came representing Defendant, Dinesh K. Shah. This motion is based on good cause in that an irreconcilable conflict has arisen between the undersigned and his client, and it has become impractical for Peter M. Blute to continue to represent Dinesh K. Shah. The withdrawal is not sought for delay, but that justice may be done. 1. No other attorney has been retained by the client to substitute. 2. A copy of this motion, notice of hearing, and notice of right to object has been delivered to the client, both by fax, certified mail posted, and regular mail on December 12, 2008. 3. By copy of this Motion, the party has been advised of his right to object to the motion, and to set a hearing on such motion. 5. The party has not given written consent to this motion. 6. Dinesh K. Shah has the following last known address: 1302 Waugh Dr. #221 Houston, Texas 77043 7. The following are settings and deadlines pending in this matter: a. Discovery responses to discovery dated July 8, 2008 are due by Defendant, Shah, no later than December 10, 2008. If there is any supplementation to such discovery, it will be governed by the Texas Rules of Civil Procedure.b. Bond hearing is scheduled by the Court for December 19, 2008 at 9:00 a.m.. 8. The client is advised that this motion has been set for oral hearing to the Court on December 19, 2008, at 9:00 a.m. You have a right to contest this motion. WHEREFORE, PREMISES CONSIDERED, Peter M. Blute respectfully requests that this Court sign the attached Order permitting him to withdraw from this cause and for all further relief to which he may be justly entitled. Respectfully submitted, Gh 11 GA. PETER M. BLUTE SBN 02521600 7676 Hillmont, Suite 150 Houston, Texas 77040 Tel.: (713) 460-5500 Fax: (713) 460-2265 ATTORNEY FOR DEFENDANT DINESH K. SHAH CERTIFICATE OF SERVICE This is to certify that the foregoing instrument was forwarded to all counsel of record by certified mail, return receipt requested, or regular mail, hand delivery, or by facsimile transmission to: Paul D. Clote Four Houston Center 1221 Lamar, Suite 1090 Houston, Texas 77010 Fax: (713) 654-0052 Jim M. Perdue, Jr. Perdue & Kidd, L.L.P. Wortham Tower 2727 Allen Parkway, Suite 800 Houston, Texas 77019 Fax: (713) 520-2525 Dinesh K. Shah 1302 Waugh Dr. #221 Houston, Texas 77043 VIA: fax transmission, regular mail and certified mailon this 12th day of December, 2008. Jk 11 late Peter M. Blute