On September 18, 2007 a
Motion,Ex Parte
was filed
involving a dispute between
Carlson, Courtney,
Carlson, Hillary,
and
Dunn, Heather,
for (CV) CIVIL COMMON PLEAS
in the District Court of Delaware County.
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IN THE COURT OF COMMON PLEAS
2 DELAWARE COUNTY, OHIO
Hillary Carlson, dba Wingate Farm, et al.,
' Ss
: : Judge W. Duncan Whitney?
* v. : = 8
1 oF =
. Heather Dunn, mo a
2= z=
Defendant “8 3
letendant. 5 e
a &
MOTION TO WITHDRAW AS COUNSEL OF RECORD
FOR PLAINTIFFS HILLARY CARLSON AND COURTNEY CARLSON
Now come David C. Barrett, Jr. and Troy A. Callicoat and the law firm of
BARRETT, EASTERDAY, CUNNINGHAM & ESELGROTH LLP (“BECE”) and
move this Court pursuant to Local Rule 13.02(B) for an Order granting their withdrawal
as counsel of record in this case for Plaintiffs Hillary Carlson and Courtney Carlson. A
memorandum in support follows.
MEMORANDUM IN SUPPORT
Movants and BECE have served as counsel of record for Plaintiff Hillary Carlson
and Courtney Carlson. Movants and BECE represent to the Court that they have grounds
for withdrawal from representation pursuant to Rule 1.16(B) of the Ohio Rules of
Professional Conduct. Plaintiffs Hillary Carlson and Courtney Carlson have been advised
in writing by movants and BECE of the specific grounds for the termination of
representation. This matter is set for trial on August 12, 2008, which provides Plaintiffs
adequate time to find new counsel. Thus, movants and BECE respectfully request that
LANG
1117
00062934859
WMOMS
; : Case No.: 07CVH 09 1117
a Plaintiffs, :
30
aa}
9 2B.
NOWHOI
“ANNO
HO Wat
ol
Lthis is an appropriate time to request formal withdraw before the trial court, and for the
trial court to grant such a motion.
WHEREFORE, David C. Barrett, Jr. and Troy A. Callicoat and the law firm of
BARRETT, EASTERDAY, CUNNINGHAM & ESELGROTH LLP pray that the Court
enter an Order permitting their withdrawal as counsel of record for Plaintiffs Hillary
Carlson and Courtney Carlson.
By: DAvid C. Barrett, Jr. (0017273)
E-mail: dbarrett@ohiocounsel.com
Troy A. Callicoat (076279)
E-mail: tcallicoat@ohiocounsel.com
BARRETT, EASTERDAY,
CUNNINGHAM & ESELGROTH LLP
7269 Sawmill Road, Suite 100
Dublin, Ohio 43016
Telephone: (614)210-1840
Facsimile: (614)210-1841CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the Motion to Withdraw,
along with the attached judgment entry, was served on this [beebay of April, 2008 by
via regular U.S. Mail, postage prepaid, upon the following:
Laura J. Martin, Esq.
131 N. Ludlow Street, Ste. 840
Dayton, Ohio 45402
Attomey for Defendant
Hillary Carlson
Courtney Carlson
Wingate Farm (Via Certified Mail)
5098 Miller-Paul Rd.
Westerville, OH 43082
David C. B: t. (0017273)
Preview
IN THE COURT OF COMMON PLEAS 2 DELAWARE COUNTY, OHIO Hillary Carlson, dba Wingate Farm, et al., ' Ss : : Judge W. Duncan Whitney? * v. : = 8 1 oF = . Heather Dunn, mo a 2= z= Defendant “8 3 letendant. 5 e a & MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR PLAINTIFFS HILLARY CARLSON AND COURTNEY CARLSON Now come David C. Barrett, Jr. and Troy A. Callicoat and the law firm of BARRETT, EASTERDAY, CUNNINGHAM & ESELGROTH LLP (“BECE”) and move this Court pursuant to Local Rule 13.02(B) for an Order granting their withdrawal as counsel of record in this case for Plaintiffs Hillary Carlson and Courtney Carlson. A memorandum in support follows. MEMORANDUM IN SUPPORT Movants and BECE have served as counsel of record for Plaintiff Hillary Carlson and Courtney Carlson. Movants and BECE represent to the Court that they have grounds for withdrawal from representation pursuant to Rule 1.16(B) of the Ohio Rules of Professional Conduct. Plaintiffs Hillary Carlson and Courtney Carlson have been advised in writing by movants and BECE of the specific grounds for the termination of representation. This matter is set for trial on August 12, 2008, which provides Plaintiffs adequate time to find new counsel. Thus, movants and BECE respectfully request that LANG 1117 00062934859 WMOMS ; : Case No.: 07CVH 09 1117 a Plaintiffs, : 30 aa} 9 2B. NOWHOI “ANNO HO Wat ol Lthis is an appropriate time to request formal withdraw before the trial court, and for the trial court to grant such a motion. WHEREFORE, David C. Barrett, Jr. and Troy A. Callicoat and the law firm of BARRETT, EASTERDAY, CUNNINGHAM & ESELGROTH LLP pray that the Court enter an Order permitting their withdrawal as counsel of record for Plaintiffs Hillary Carlson and Courtney Carlson. By: DAvid C. Barrett, Jr. (0017273) E-mail: dbarrett@ohiocounsel.com Troy A. Callicoat (076279) E-mail: tcallicoat@ohiocounsel.com BARRETT, EASTERDAY, CUNNINGHAM & ESELGROTH LLP 7269 Sawmill Road, Suite 100 Dublin, Ohio 43016 Telephone: (614)210-1840 Facsimile: (614)210-1841CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the Motion to Withdraw, along with the attached judgment entry, was served on this [beebay of April, 2008 by via regular U.S. Mail, postage prepaid, upon the following: Laura J. Martin, Esq. 131 N. Ludlow Street, Ste. 840 Dayton, Ohio 45402 Attomey for Defendant Hillary Carlson Courtney Carlson Wingate Farm (Via Certified Mail) 5098 Miller-Paul Rd. Westerville, OH 43082 David C. B: t. (0017273)