Preview
Filing # 90129645 E-Filed 05/26/2019 01:06:43 PM HE 11TH
JUDICIAL CIRCUIT OF FLORIDA,
IN AND FOR MIAMI-DADE COUNTY
CASE NO: 2018-032555 CA-01 (13)
JUTA BOLANGIN, : CIRCUIT CIVIL DIVISION
g Plaintiff :
w8S vs. aeiite MOTION TO WITHDRAW AS COUNSEL FOR
3 + DEFENDANT, BLUE. JAY TRUCKING. INC.
g a . BLUE.JAY. TRUCKING, ING, .and IMPACT :
BA LOGISTICS. SERVICES, LLC, .
8 Defendants. .
COMES .NOW the LAW. OFFICE .OF: CHARLES F. ATWOOD III and moves this
Honorable Court for Leave to Withdraw as Counsel for the Defendant, BLUE JAY
TRUCKING, INC., and, as grounds therefor, would respectfully show unto this
Court, as follows:
1. Undersigned Counsel filed a Notice of Appearance in the above
matter solely to prevent to entrance of a Default against the named Defendant,
BLUE JAY TRUCKING, INC., while the attorneys for the insurance carriers for
that Defendant determined coverage and retained the new law firm of FOX ROTHS-
CHILD, LLP. to represent BLUE JAY TRUCKING, INC., which law firm, by and through|
its Counsel, MICHAEL A. SASTRE, Esquire, bas already filed an Appearance and a
Motion to Dismiss.
2. Counsel for BLUE JAY TRUCKING, INC. and IMPACT LOGISTICS SERVICES
LLC have been contacted and neither have any objections to the undersigned
withdrawing as Counsel or Co-Counsél for the Defendant, BLUE JAY TRUCKING, INC.)
3. Accordingly, the undersigned Counsel respectfully prays this
Honorable Court for entry of an Order allowing CHARLES F. ATWOOD III, Esquire
to withdraw and allowing the litigation in the instant matter to proceed
MIAMI, FLORIDA 33186-5857
MAILING ADDRESS: P.O. BOX 166108, MIAMI, FL 33116-6108
LAW OFFICES OF CHARLES F. ATWOOD It
13380 S.W. 131st STREET, SUITE 119
€-MAIL: UMLAW72@A0L.COM
CHARLES F. ATWOOD II
through whatever course this Court allows.
WHEREFORE, Defendant, BLUE JAY TRUCKING, INC., and its Counsel pray
this Honorable Court for Leave to Withdraw as Counsel for BLUE JAY TRUCKING,
INC, in the above matter and for such other and further relief as this Court
may deem apprpriate and proper.
I HEREBY CERTIFY that a true copy of the above was mailed and tele—
faxed this _ 4 Z day of December, 2018 to: MICHAEL A. SASTRE, Esquire, FOX
ROTHSCHILD, LLP, Two South Biscayne Boulevard, Suite 2750, Miami, Florida
33131-1833 - E-MAIL: wmsastre@foxrothschild.com and RYAN M. CLANCY, Esquire,
NEW
TELEFAX
305-238-9400AINSWORTH + CLANCY, Attorney for Plaintiff, 1111 Brickell Avenue, 11th Floor,
Miami, Florida 33131 - E-MAIL: ryan@business—esq.com
NEW
TELEPHONE
305-238-9200
LAW OFFICE OF CHARLES F. ATWOOD III
. Attorney for BLUE JAY TRUCKING, INC.
P.O. Box 166108
Miami, Florida 33016-6108
Telephone: (305)-238-9200
Telefax: (305)-238-9400
Electronic Mail Address: umlaw/2@aol.com
8
= 5
_ oO
8 3 Fla. Bar #0145693
Ze =
)
“i ff
NOTARY Avtate, STATE OF FLORIDA
My Commission Expires:
My Commission No:
PERSONALLY KNOWN TO ME
to-do lta a Scttnl tee
JOSEFINA C. ARRIETA
Notary Public - State of Florida
Commission # FF 221536 0 *
Lat
Expires Ast 16, 201¢*IN TH. .IRCULT COURT OF THE 11TH
JUDICIAL CIRCUIT OF FLORIDA,
AN FOR FOR MIAMI-DADE COUNTY
CASE NO: 2018-@32555 CA-01 (13)
JUTA BOIANGIN, : CIRCUIT CIVIL DIVISION
Plaintiff, z
AGREED
vs. . ORDER GRANTING
: MOTION TO WITHDRAW
BLUE JAY TRUCKING, INC, and IMPACT LOGISTICS z
SERVICES, LLC,
Defendants.
THIS CAUSE coming on to be heard before the Court, on April 4, 2019, on
the MOTION OF THE LAW OFFICE OF CHARLES F. ATWOOD III TO WITHDRAW AS COUNSEL FOR
DEFENDANT, BLUE JAY TRUCKING, INC., and appropriate Notice having been given, IT
IS HEREBY ORDERED AND ADJUDGED as follows:
1. That the MOTION OF THE LAW OFFICE OF CHARLES F. ATWOOD III TO WITHDRAW
AS COUNSEL FOR DEFENDANT, BLUE JAY TRUCKING, INC, be and the same is hereby granted.
2. The Clerk of this Court is hereby directed to remove CHARLES F. ATWOOD
III, Esquire from the docket and records for this case.
DONE AND ORDERED, in Chambers, at Miami, Miami-Dade County, Florida this
day of ,» 2019,
JUDGE OF THE CIRCUIT COURT
Copies furnished:
LAW OFFICE OF CHARLES F. ATWOOD III
umlaw72@aol.com
FOX ROTHSCHILD, LLP
AARON H. EPSTEIN, Esquire
aepsteon@foxrothschild.com
AINSWORTH + CLANCY
RYAN M. CLANCY, Esquire
ryan@business-esq.com
Preview
Filing # 90129645 E-Filed 05/26/2019 01:06:43 PM HE 11TH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR MIAMI-DADE COUNTY CASE NO: 2018-032555 CA-01 (13) JUTA BOLANGIN, : CIRCUIT CIVIL DIVISION g Plaintiff : w8S vs. aeiite MOTION TO WITHDRAW AS COUNSEL FOR 3 + DEFENDANT, BLUE. JAY TRUCKING. INC. g a . BLUE.JAY. TRUCKING, ING, .and IMPACT : BA LOGISTICS. SERVICES, LLC, . 8 Defendants. . COMES .NOW the LAW. OFFICE .OF: CHARLES F. ATWOOD III and moves this Honorable Court for Leave to Withdraw as Counsel for the Defendant, BLUE JAY TRUCKING, INC., and, as grounds therefor, would respectfully show unto this Court, as follows: 1. Undersigned Counsel filed a Notice of Appearance in the above matter solely to prevent to entrance of a Default against the named Defendant, BLUE JAY TRUCKING, INC., while the attorneys for the insurance carriers for that Defendant determined coverage and retained the new law firm of FOX ROTHS- CHILD, LLP. to represent BLUE JAY TRUCKING, INC., which law firm, by and through| its Counsel, MICHAEL A. SASTRE, Esquire, bas already filed an Appearance and a Motion to Dismiss. 2. Counsel for BLUE JAY TRUCKING, INC. and IMPACT LOGISTICS SERVICES LLC have been contacted and neither have any objections to the undersigned withdrawing as Counsel or Co-Counsél for the Defendant, BLUE JAY TRUCKING, INC.) 3. Accordingly, the undersigned Counsel respectfully prays this Honorable Court for entry of an Order allowing CHARLES F. ATWOOD III, Esquire to withdraw and allowing the litigation in the instant matter to proceed MIAMI, FLORIDA 33186-5857 MAILING ADDRESS: P.O. BOX 166108, MIAMI, FL 33116-6108 LAW OFFICES OF CHARLES F. ATWOOD It 13380 S.W. 131st STREET, SUITE 119 €-MAIL: UMLAW72@A0L.COM CHARLES F. ATWOOD II through whatever course this Court allows. WHEREFORE, Defendant, BLUE JAY TRUCKING, INC., and its Counsel pray this Honorable Court for Leave to Withdraw as Counsel for BLUE JAY TRUCKING, INC, in the above matter and for such other and further relief as this Court may deem apprpriate and proper. I HEREBY CERTIFY that a true copy of the above was mailed and tele— faxed this _ 4 Z day of December, 2018 to: MICHAEL A. SASTRE, Esquire, FOX ROTHSCHILD, LLP, Two South Biscayne Boulevard, Suite 2750, Miami, Florida 33131-1833 - E-MAIL: wmsastre@foxrothschild.com and RYAN M. CLANCY, Esquire, NEW TELEFAX 305-238-9400AINSWORTH + CLANCY, Attorney for Plaintiff, 1111 Brickell Avenue, 11th Floor, Miami, Florida 33131 - E-MAIL: ryan@business—esq.com NEW TELEPHONE 305-238-9200 LAW OFFICE OF CHARLES F. ATWOOD III . Attorney for BLUE JAY TRUCKING, INC. P.O. Box 166108 Miami, Florida 33016-6108 Telephone: (305)-238-9200 Telefax: (305)-238-9400 Electronic Mail Address: umlaw/2@aol.com 8 = 5 _ oO 8 3 Fla. Bar #0145693 Ze = ) “i ff NOTARY Avtate, STATE OF FLORIDA My Commission Expires: My Commission No: PERSONALLY KNOWN TO ME to-do lta a Scttnl tee JOSEFINA C. ARRIETA Notary Public - State of Florida Commission # FF 221536 0 * Lat Expires Ast 16, 201¢*IN TH. .IRCULT COURT OF THE 11TH JUDICIAL CIRCUIT OF FLORIDA, AN FOR FOR MIAMI-DADE COUNTY CASE NO: 2018-@32555 CA-01 (13) JUTA BOIANGIN, : CIRCUIT CIVIL DIVISION Plaintiff, z AGREED vs. . ORDER GRANTING : MOTION TO WITHDRAW BLUE JAY TRUCKING, INC, and IMPACT LOGISTICS z SERVICES, LLC, Defendants. THIS CAUSE coming on to be heard before the Court, on April 4, 2019, on the MOTION OF THE LAW OFFICE OF CHARLES F. ATWOOD III TO WITHDRAW AS COUNSEL FOR DEFENDANT, BLUE JAY TRUCKING, INC., and appropriate Notice having been given, IT IS HEREBY ORDERED AND ADJUDGED as follows: 1. That the MOTION OF THE LAW OFFICE OF CHARLES F. ATWOOD III TO WITHDRAW AS COUNSEL FOR DEFENDANT, BLUE JAY TRUCKING, INC, be and the same is hereby granted. 2. The Clerk of this Court is hereby directed to remove CHARLES F. ATWOOD III, Esquire from the docket and records for this case. DONE AND ORDERED, in Chambers, at Miami, Miami-Dade County, Florida this day of ,» 2019, JUDGE OF THE CIRCUIT COURT Copies furnished: LAW OFFICE OF CHARLES F. ATWOOD III umlaw72@aol.com FOX ROTHSCHILD, LLP AARON H. EPSTEIN, Esquire aepsteon@foxrothschild.com AINSWORTH + CLANCY RYAN M. CLANCY, Esquire ryan@business-esq.com