On September 16, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Liberty County Texas,
Master File,
and
Arkema Inc Litigation,
Arkema S A,
Bureau Veritas North America Inc,
Centerpoint Energy Houston Electric Llc,
Centerpoint Energy Inc,
Coolsys Entery Design Llc,
Dacon Corporation,
Dashiell Corporation,
Infinity Construction Group Llc,
Infinity Construction Llc,
Infinity Construction Services Lp,
In Re,
In Re Arkema Inc Litigation,
Loftin Equipment Company,
M&I Electric Llc,
Praxair Inc,
Praxair Services Inc,
Seaboard Controls Llc,
Service Refrigeration Llc,
Star Service Inc,
Star Service Inc Of Houston,
for MDL - Arkema Inc
in the District Court of Harris County.
Preview
MASTER DOCKET NO. 2020-61765-MDL
IN THE DISTRICT COURT OF
§
IN RE: §
§ HARRIS COUNTY, TEXAS
ARKEMA INC. LITIGATION §
§ 333 JUDICIAL DISTRICT
CAUSE NO. 2017-58465
CHRISTY GRAVES, et al., IN THE DISTRICT COURT OF
JUDICICAL DISTRICT
ARKEMA, INC. et al., HARRIS COUNTY, TEXAS
CONSOLIDATED CASES
CAUSE NO. 2019-60480
CHRISTY GRAVES, et al., IN THE DISTRICT COURT OF
JUDICICAL DISTRICT
ARKEMA, INC. et al., HARRIS COUNTY, TEXAS
CAUSE NO. 2019-60565
BRICE ABBOTT, JR., et al., IN THE DISTRICT COURT OF
JUDICICAL DISTRICT
ARKEMA, INC., ARKEMA, S.A.,
BUREAU VERITAS NORTH AMERICA,
INC., CENTERPOINT ENERGY, INC.,
et al., HARRIS COUNTY, TEXAS
CAUSE NO. 2019-60384
VALERIE AUZENNE, et al., IN THE DISTRICT COURT OF
JUDICICAL DISTRICT
ARKEMA, INC., ARKEMA, S.A.,
BUREAU VERITAS NORTH AMERICA,
INC., CENTERPOINT ENERGY, INC.,
et al., HARRIS COUNTY, TEXAS
PLAINTIFF'S MOTION TO WITHDRAW AS COUNSEL OR PLAINTIFF
THA HUY NGUYEN
COME NOW, MUHAMMAD S. AZIZ and the law firm of ABRAHAM, WATKINS,
NICHOLS, AGOSTO, AZIZ STOGNER, attorneys for Plaintiff, THA HUY NGUYEN,
in the abovestyled and numbered cause of action, and respectfully request permission from
this Honorable Court to withdraw attorneys record for Plaintiff, a Huy Nguyen and
support thereof, would respectfully show this Honorable Court as follows:
This motion is based on good cause and upon ethical reasons surrounding
the attorney client relationship. The withdrawal is not sought for delay, but so that justice
may be served.
In accordance with Texas Rule of Civil Procedure 10, a written notice is
being forwarded Plaintiff, Tha Huy Nguyen advising Plaintiff that this motion being
filed and that Plaintiff has right object this motion writing. copy this motion
being forwarded certified mail, return receipt requested Tha Huy Nguyen their last
known address All known contact information associated with Plaintiffs is:
13250 Southpoint Lane
Houston, TX 77034
Pursuant to this Court's requirements, Counsel for Plaintiff has sent
correspondence to Plaintiff, informing them of the withdrawal, including the withdrawal
motion with the correspondence and further notifying the Plaintiff of the following:
We are formally withdrawing as your attorneys for your claims in this case;
By way of this correspondence and others previously mailed to you, you are
deemed to have knowledge of and are required to abide by the Texas Rules of
Civil Procedure should you choose to proceed as pro se;
All notices from the Court to the your current address will be deemed to have
been received unless you notify the Court of any change of address;
No continuances or extension will be granted to the pro se client in order to
obtain other counsel;
Notice of submission or hearing at which the motion to withdraw will be
considered.
Further, pursuant to Texas Disciplinary Rule l.15(b)(5), a lawyer may
withdraw representation if "the client fails substantially to fulfill an obligation to the lawyer
regarding the lawyer's services, including an obligation to pay the lawyer's fee as agreed,
and has been given reasonable warning that the lawyer will withdraw unless the obligation
is fulfilled." Additionally, pursuant to Texas Disciplinary Rule 1.15(b)(7), other good
cause for withdrawal exists. Despite repeated requests, Plaintiff has not fulfilled their
obligation to comply with the requirements of the discovery process. Plaintiff was given
clear and reasonable warnings that representation would be withdrawn if Plaintiff did not
remedy such noncompliance. Plaintiff has yet to fulfill their obligation, thus, good cause
exists for the withdrawal from representation.
This case currently is not set on the Court's trial docket.
WHEREFORE, Muhammad S. Aziz respectfully requests that this Court
enter Order permitting him and the law firm of Abraham, Watkins, Nichols, Agosto,
Aziz & Stogner to withdraw from representation of Plaintiff.
Respectfully submitted,
ABRAHAM, WATKINS, NICHOLS,
AGOSTO, AZIZ & STOGNER
/s/ Muhammad S. Aziz
MUHAMMAD S. AZIZ
Texas Bar. No. 24043538
800 Commerce Street
Houston, Texas 77002
(713) 222
(713) 225 Facsimile
maziz@awtxlaw.com
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument was served on all
rd
counsel of record on this day of Ju pursuant to the Texas Rules of Civil Procedure.
/s/ Muhammad S. Aziz
MUHAMMAD S. AZIZ
Preview
MASTER DOCKET NO. 2020-61765-MDL IN THE DISTRICT COURT OF § IN RE: § § HARRIS COUNTY, TEXAS ARKEMA INC. LITIGATION § § 333 JUDICIAL DISTRICT CAUSE NO. 2017-58465 CHRISTY GRAVES, et al., IN THE DISTRICT COURT OF JUDICICAL DISTRICT ARKEMA, INC. et al., HARRIS COUNTY, TEXAS CONSOLIDATED CASES CAUSE NO. 2019-60480 CHRISTY GRAVES, et al., IN THE DISTRICT COURT OF JUDICICAL DISTRICT ARKEMA, INC. et al., HARRIS COUNTY, TEXAS CAUSE NO. 2019-60565 BRICE ABBOTT, JR., et al., IN THE DISTRICT COURT OF JUDICICAL DISTRICT ARKEMA, INC., ARKEMA, S.A., BUREAU VERITAS NORTH AMERICA, INC., CENTERPOINT ENERGY, INC., et al., HARRIS COUNTY, TEXAS CAUSE NO. 2019-60384 VALERIE AUZENNE, et al., IN THE DISTRICT COURT OF JUDICICAL DISTRICT ARKEMA, INC., ARKEMA, S.A., BUREAU VERITAS NORTH AMERICA, INC., CENTERPOINT ENERGY, INC., et al., HARRIS COUNTY, TEXAS PLAINTIFF'S MOTION TO WITHDRAW AS COUNSEL OR PLAINTIFF THA HUY NGUYEN COME NOW, MUHAMMAD S. AZIZ and the law firm of ABRAHAM, WATKINS, NICHOLS, AGOSTO, AZIZ STOGNER, attorneys for Plaintiff, THA HUY NGUYEN, in the abovestyled and numbered cause of action, and respectfully request permission from this Honorable Court to withdraw attorneys record for Plaintiff, a Huy Nguyen and support thereof, would respectfully show this Honorable Court as follows: This motion is based on good cause and upon ethical reasons surrounding the attorney client relationship. The withdrawal is not sought for delay, but so that justice may be served. In accordance with Texas Rule of Civil Procedure 10, a written notice is being forwarded Plaintiff, Tha Huy Nguyen advising Plaintiff that this motion being filed and that Plaintiff has right object this motion writing. copy this motion being forwarded certified mail, return receipt requested Tha Huy Nguyen their last known address All known contact information associated with Plaintiffs is: 13250 Southpoint Lane Houston, TX 77034 Pursuant to this Court's requirements, Counsel for Plaintiff has sent correspondence to Plaintiff, informing them of the withdrawal, including the withdrawal motion with the correspondence and further notifying the Plaintiff of the following: We are formally withdrawing as your attorneys for your claims in this case; By way of this correspondence and others previously mailed to you, you are deemed to have knowledge of and are required to abide by the Texas Rules of Civil Procedure should you choose to proceed as pro se; All notices from the Court to the your current address will be deemed to have been received unless you notify the Court of any change of address; No continuances or extension will be granted to the pro se client in order to obtain other counsel; Notice of submission or hearing at which the motion to withdraw will be considered. Further, pursuant to Texas Disciplinary Rule l.15(b)(5), a lawyer may withdraw representation if "the client fails substantially to fulfill an obligation to the lawyer regarding the lawyer's services, including an obligation to pay the lawyer's fee as agreed, and has been given reasonable warning that the lawyer will withdraw unless the obligation is fulfilled." Additionally, pursuant to Texas Disciplinary Rule 1.15(b)(7), other good cause for withdrawal exists. Despite repeated requests, Plaintiff has not fulfilled their obligation to comply with the requirements of the discovery process. Plaintiff was given clear and reasonable warnings that representation would be withdrawn if Plaintiff did not remedy such noncompliance. Plaintiff has yet to fulfill their obligation, thus, good cause exists for the withdrawal from representation. This case currently is not set on the Court's trial docket. WHEREFORE, Muhammad S. Aziz respectfully requests that this Court enter Order permitting him and the law firm of Abraham, Watkins, Nichols, Agosto, Aziz & Stogner to withdraw from representation of Plaintiff. Respectfully submitted, ABRAHAM, WATKINS, NICHOLS, AGOSTO, AZIZ & STOGNER /s/ Muhammad S. Aziz MUHAMMAD S. AZIZ Texas Bar. No. 24043538 800 Commerce Street Houston, Texas 77002 (713) 222 (713) 225 Facsimile maziz@awtxlaw.com ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was served on all rd counsel of record on this day of Ju pursuant to the Texas Rules of Civil Procedure. /s/ Muhammad S. Aziz MUHAMMAD S. AZIZ