Preview
DC-15-07174
JOHN DOE I, Individually and as Next Friend IN THE DISTRICT COURT
of JOHN DOE II, a Minor,
Plaintiffs,
Vv.
THE ANDERSON PRIVATE SCHOOL, 44TH JUDICIAL DISTRICT
§
§
§
§
§
§
‘
WILLIAM C. ANDERSON, Individually, §
LEVONNA C. ANDERSON, Individually, §
ALEXANDER A. ANDERSON, Individually §
RIPLEY ENTERTAINMENT, INC., and JIM §
PATTISON U.S.A., INC., §
§
Defendants, §
§
§
DALLAS COUNTY, TEXAS
MOTION FOR SUBTITUTION OF COUNSEL
NOW COMES, The Anderson Private School, William C. Anderson, Individually,
Levonna Anderson, Individually, and Alexander Anderson, Individually, Defendants herein, and
request leave of Court to substitute William Kincaid for Greg Westfall, Monroe Solomon III, and
The Westfall Firm as the attorneys of record for Defendants in the above-entitled and numbered
cause. In support thereof, Defendants would show the Court as follows:
1. Substitution and withdrawal of Greg Westfall and Monroe Solomon III is necessary
because Defendants have hired William Kincaid as their attorney to represent them in the
above-entitled matter, as evidenced by the signatures of attorney William Kincaid and
Monroe Solomon III appearing below.
2. A proposed order is submitted with this Motion providing for the withdrawal of Greg
Westfall and Monroe Solomon III, and for the substitution of William Kincaid as counsel for
Defendants.WHEREFORE, PREMISES CONSIDERED, Defendants, The Anderson Private School,
William C. Anderson, Individually, Levonna Anderson, Individually, and Alexander
Anderson, Individually, pray that the Court enter an order that Greg Westfall and Monroe
Solomon III withdraw as counsel and substitute William Kincaid as their attorney of
record and for such other and further relief, in law and in equity, to which they may be
entitled.
Respectfully submitted,
William A. Ae
State Bar of Texas: 11431500
P.O. Box 457
Sanger, TX 76266
whk4888@yahoo,com
ATTORNEY FOR DEFENDANTS ANDERSON
lonroe Solomon III
State Bar No. 24091486
The Westfall Firm
4200 West Vickery Blvd.,
Second Floor
Fort Worth, TX 76107
(817) 928-4222 (P)
(817) 385-6715 (F)
Email: monroe@westfallfirm.com
Motion for Substitution of Counsel
Page 2 of 3CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing has been sent via email this
the 2-O_ day of August, 2015, by to:
VIA EMAIL:
John D, Sloan, Jr.
Douglas W. Lukasik
SLOAN MATNEY, LLP
3838 Oak Lawn Ave., Suite 1200
Dallas, TX 75219
jsloan@sloanmatney.com
dlukasik@sloanmatncy.com
Counsel for Plaintiffs
S. Todd Parks
Jennifer French — Paralegal to Todd Parks
Walters, Balido & Crain, LLP
10440 N. Central Expressway, Suite 1500
Dallas, TX 75231
Todd.Parks@wbclawfirm.com
Jennifer. French@wbclawfirm.com
Counsel for Defendants Ripley and Pattison
Motion for Substitution of Counsel
Page 3 of 3
Preview
DC-15-07174 JOHN DOE I, Individually and as Next Friend IN THE DISTRICT COURT of JOHN DOE II, a Minor, Plaintiffs, Vv. THE ANDERSON PRIVATE SCHOOL, 44TH JUDICIAL DISTRICT § § § § § § ‘ WILLIAM C. ANDERSON, Individually, § LEVONNA C. ANDERSON, Individually, § ALEXANDER A. ANDERSON, Individually § RIPLEY ENTERTAINMENT, INC., and JIM § PATTISON U.S.A., INC., § § Defendants, § § § DALLAS COUNTY, TEXAS MOTION FOR SUBTITUTION OF COUNSEL NOW COMES, The Anderson Private School, William C. Anderson, Individually, Levonna Anderson, Individually, and Alexander Anderson, Individually, Defendants herein, and request leave of Court to substitute William Kincaid for Greg Westfall, Monroe Solomon III, and The Westfall Firm as the attorneys of record for Defendants in the above-entitled and numbered cause. In support thereof, Defendants would show the Court as follows: 1. Substitution and withdrawal of Greg Westfall and Monroe Solomon III is necessary because Defendants have hired William Kincaid as their attorney to represent them in the above-entitled matter, as evidenced by the signatures of attorney William Kincaid and Monroe Solomon III appearing below. 2. A proposed order is submitted with this Motion providing for the withdrawal of Greg Westfall and Monroe Solomon III, and for the substitution of William Kincaid as counsel for Defendants.WHEREFORE, PREMISES CONSIDERED, Defendants, The Anderson Private School, William C. Anderson, Individually, Levonna Anderson, Individually, and Alexander Anderson, Individually, pray that the Court enter an order that Greg Westfall and Monroe Solomon III withdraw as counsel and substitute William Kincaid as their attorney of record and for such other and further relief, in law and in equity, to which they may be entitled. Respectfully submitted, William A. Ae State Bar of Texas: 11431500 P.O. Box 457 Sanger, TX 76266 whk4888@yahoo,com ATTORNEY FOR DEFENDANTS ANDERSON lonroe Solomon III State Bar No. 24091486 The Westfall Firm 4200 West Vickery Blvd., Second Floor Fort Worth, TX 76107 (817) 928-4222 (P) (817) 385-6715 (F) Email: monroe@westfallfirm.com Motion for Substitution of Counsel Page 2 of 3CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing has been sent via email this the 2-O_ day of August, 2015, by to: VIA EMAIL: John D, Sloan, Jr. Douglas W. Lukasik SLOAN MATNEY, LLP 3838 Oak Lawn Ave., Suite 1200 Dallas, TX 75219 jsloan@sloanmatney.com dlukasik@sloanmatncy.com Counsel for Plaintiffs S. Todd Parks Jennifer French — Paralegal to Todd Parks Walters, Balido & Crain, LLP 10440 N. Central Expressway, Suite 1500 Dallas, TX 75231 Todd.Parks@wbclawfirm.com Jennifer. French@wbclawfirm.com Counsel for Defendants Ripley and Pattison Motion for Substitution of Counsel Page 3 of 3