On June 16, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Nationstar Mortgage Llc,
and
Countrywide Home Loans Inc,
Roark, Kelley S,
Mortgage Electronic Registration Systems, Inc.,
Roark, Kelley,
for RPMF -Homestead ($250,000 or more)
in the District Court of Miami-Dade County.
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Filing # 67755094 E-Filed 02/09/2018 12:00:15 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL
CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
NATIONSTAR MORTGAGE LLC, CIRCUIT CIVIL DIVISON
Plaintiff, CASE NO. 2017-014514 CA 11
vs.
KELLEY S. ROARK, et al.,
Defendants.
/
GRAHAM LEGAL, P.A,’S AMENDED MOTION TO
WITHDRAW AS COUNSEL FOR DEFENDANT KELLEY S. ROARK
Graham Legal, P.A., counsel for Defendant Kelley S. Roark files this
amended motion to withdraw, and in support thereof states as follows:
1. Irreconcilable differences have arisen between undersigned counsel and
Defendant Kelley S. Roark.
2. This motion is made in good faith and not for purposes of delay.
3. No harm or prejudice will result to plaintiff in the event this motion is
granted.
4. Defendant Kelley S. Roark has no objection to undersigned’s motion to
withdraw as counsel. See Client Consent for Graham Legal, P.A. to Withdraw as
Counsel signed by defendant Kelley S. Roark as “Exhibit A”.
1
Graham Legal, P.A. * 814 Ponce de Leon Boulevard * Suite 410 * Coral Gables, Florida 33134 * Telephone 305.445.9185CASE NO. 2017-014514 CA 11
5. Further pleadings and correspondence in this case should be directed to
Defendant Kelley S. Roark at 12135 NE 10 Avenue, Miami, Florida 33161.
WHEREFORE the law firm of Graham Legal, P.A. respectfully requests
that this court enter an order granting its motion to withdraw.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was
served by eservice to Laura Fabricio, Esquire, mail@rasflaw.com; Ifabricio@
rasflaw.com, Robertson, Anschutz & Schneid, P.L., Attorneys for Plaintiff, 6409
Congress Avenue, Suite 100, Boca Raton, Florida 33487 and served by U.S.
Certified Mail to defendant Kelley S. Roark, Return Receipt No. 7017 3040 0000
2435 9946, 12135 NE 10 Avenue, Miami, Florida 33161 on February 9, 2018.
GRAHAM LEGAL, P.A.
Counsel for Defendant Roark
Ponce Plaza, Suite 410
814 Ponce de Leon Boulevard
Coral Gables, Florida 33134
Telephone (305) 445-9185
Telecopier (305) 444-8015
eservice@grahamlegalpa.com
By: s/ Dillan Galan
H. Dillon Graham, III, Esquire
Florida Bar Number 0371955
2
Graham Legal, P.A. * 814 Ponce de Leon Boulevard * Suite 410 * Coral Gables, Florida 33134 * Telephone 305.445.9185Nationstar Mortgage, LLC v. Kelley S. Roark, et al.
Miami-Dade Circuit Case No. 2017-014514 CA 11
CLIENT CONSENT FOR GRAHAM LEGAL, P.A. TO
WITHDRAW AS CO! LOFR IRD FOR DEFENDANT
Defendant Kelley S. Roark pursuant to applicable rules of the Florida Rules of
Civil Procedure hereby consents to the withdrawal of Graham Legal, P.A. as her
counsel of record in the above captioned matter effective immediately upon the entry
of an order by this court granting counsel’s motion to withdraw that is sent to the
client by U.S. Mail.
/
By? . g AN
Kelley S$. Roark, Defendant
Dated: Heb// Ze
Exhibit
“A”
Document Filed Date
February 09, 2018
Case Filing Date
June 16, 2017
Category
RPMF -Homestead ($250,000 or more)
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Filing # 67755094 E-Filed 02/09/2018 12:00:15 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA NATIONSTAR MORTGAGE LLC, CIRCUIT CIVIL DIVISON Plaintiff, CASE NO. 2017-014514 CA 11 vs. KELLEY S. ROARK, et al., Defendants. / GRAHAM LEGAL, P.A,’S AMENDED MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANT KELLEY S. ROARK Graham Legal, P.A., counsel for Defendant Kelley S. Roark files this amended motion to withdraw, and in support thereof states as follows: 1. Irreconcilable differences have arisen between undersigned counsel and Defendant Kelley S. Roark. 2. This motion is made in good faith and not for purposes of delay. 3. No harm or prejudice will result to plaintiff in the event this motion is granted. 4. Defendant Kelley S. Roark has no objection to undersigned’s motion to withdraw as counsel. See Client Consent for Graham Legal, P.A. to Withdraw as Counsel signed by defendant Kelley S. Roark as “Exhibit A”. 1 Graham Legal, P.A. * 814 Ponce de Leon Boulevard * Suite 410 * Coral Gables, Florida 33134 * Telephone 305.445.9185CASE NO. 2017-014514 CA 11 5. Further pleadings and correspondence in this case should be directed to Defendant Kelley S. Roark at 12135 NE 10 Avenue, Miami, Florida 33161. WHEREFORE the law firm of Graham Legal, P.A. respectfully requests that this court enter an order granting its motion to withdraw. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served by eservice to Laura Fabricio, Esquire, mail@rasflaw.com; Ifabricio@ rasflaw.com, Robertson, Anschutz & Schneid, P.L., Attorneys for Plaintiff, 6409 Congress Avenue, Suite 100, Boca Raton, Florida 33487 and served by U.S. Certified Mail to defendant Kelley S. Roark, Return Receipt No. 7017 3040 0000 2435 9946, 12135 NE 10 Avenue, Miami, Florida 33161 on February 9, 2018. GRAHAM LEGAL, P.A. Counsel for Defendant Roark Ponce Plaza, Suite 410 814 Ponce de Leon Boulevard Coral Gables, Florida 33134 Telephone (305) 445-9185 Telecopier (305) 444-8015 eservice@grahamlegalpa.com By: s/ Dillan Galan H. Dillon Graham, III, Esquire Florida Bar Number 0371955 2 Graham Legal, P.A. * 814 Ponce de Leon Boulevard * Suite 410 * Coral Gables, Florida 33134 * Telephone 305.445.9185Nationstar Mortgage, LLC v. Kelley S. Roark, et al. Miami-Dade Circuit Case No. 2017-014514 CA 11 CLIENT CONSENT FOR GRAHAM LEGAL, P.A. TO WITHDRAW AS CO! LOFR IRD FOR DEFENDANT Defendant Kelley S. Roark pursuant to applicable rules of the Florida Rules of Civil Procedure hereby consents to the withdrawal of Graham Legal, P.A. as her counsel of record in the above captioned matter effective immediately upon the entry of an order by this court granting counsel’s motion to withdraw that is sent to the client by U.S. Mail. / By? . g AN Kelley S$. Roark, Defendant Dated: Heb// Ze Exhibit “A”