rowe withdraw

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1 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA ) DOUG FRIESEN, ) Plaintiff, ) ) v. ) Case No. CIV 10-140-C ) CHARLES N. ERB, Jr., ) Defendant. ) ) JACOB L. ROWE’S MOTION TO WITHDRAW AS ATTORNEY OF RECORD FOR PLAINTIFF DOUG FRIESEN COMES NOW Jacob L. Rowe, attorney of record for Doug Friesen and moves this Court for an order withdrawing his appearance as counsel of record for Plaintiff, Doug Friesen and presents to the Court the following: 1. Jacob L. Rowe (“Rowe”) entered his appearance for Plaintiff at the onset of this action. 2. Circumstances have arisen which prevent Rowe’s effective representation of Plaintiff in this matter. 3. This matter is currently scheduled for trial on this Court’s trial docket for September 10, 2012. 4. Plaintiff has been apprised of and is aware of all deadlines within this Court’s Order (Dkt. 52) filed on March 8, 2012. 5. Plaintiff recently received deposition notices for his deposition as well as Mack Martin’s deposition and the same have been scheduled for May 17 th and 18 th, respectively. Case 5:10-cv-00140-C Document 56 Filed 05/02/12 Page 1 of 3

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Page 1: Rowe Withdraw

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IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF OKLAHOMA

)

DOUG FRIESEN, )

Plaintiff, )

)

v. ) Case No. CIV 10-140-C

)

CHARLES N. ERB, Jr., )

Defendant. )

)

JACOB L. ROWE’S MOTION TO WITHDRAW AS

ATTORNEY OF RECORD FOR PLAINTIFF DOUG FRIESEN

COMES NOW Jacob L. Rowe, attorney of record for Doug Friesen and moves

this Court for an order withdrawing his appearance as counsel of record for Plaintiff,

Doug Friesen and presents to the Court the following:

1. Jacob L. Rowe (“Rowe”) entered his appearance for Plaintiff at the onset of this

action.

2. Circumstances have arisen which prevent Rowe’s effective representation of

Plaintiff in this matter.

3. This matter is currently scheduled for trial on this Court’s trial docket for

September 10, 2012.

4. Plaintiff has been apprised of and is aware of all deadlines within this Court’s

Order (Dkt. 52) filed on March 8, 2012.

5. Plaintiff recently received deposition notices for his deposition as well as Mack

Martin’s deposition and the same have been scheduled for May 17th

and 18th,

respectively.

Case 5:10-cv-00140-C Document 56 Filed 05/02/12 Page 1 of 3

Page 2: Rowe Withdraw

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6. Rowe hereby certifies that he has personally apprised Plaintiff of this request to

withdraw and Plaintiff does not object to the same.

7. Rowe has discussed this matter with opposing counsel Joseph Wells who has

neither consented, nor objected to Rowe’s withdrawal, but who has indicated he

will file a response to the same.

8. To Rowe’s knowledge, no successor counsel has been named.

9. Plaintiff is prepared to enter an appearance pro se immediately upon the date of

any order withdrawing Rowe from this case.

10. Plaintiff does not request that this matter be continued.

10. This motion has been hand delivered to Plaintiff.

Respectfully submitted,

/S/ JACOB L. ROWE

____________________________________

Jacob L. Rowe, OBA No. 21797

Jacob L. Rowe, P.C.

1309 N. Shartel Avenue

Oklahoma City, OK 73103

Phone - 405-239-2722

Fax - 405-235-2453

Attorney for Plaintiff

JURY TRIAL DEMANDED

ATTORNEY'S LIEN CLAIMED

Case 5:10-cv-00140-C Document 56 Filed 05/02/12 Page 2 of 3

Page 3: Rowe Withdraw

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CERTIFICATE OF SERVICE

I hereby certify that on May 2, 2012 I electronically transmitted the above

document to the Clerk of Court using the ECF System for filing for service upon the

Joseph L. Wells

3955 N.W. 23rd

Street

Oklahoma City, Oklahoma 73107

Attorney for Defendant

/S/ JACOB L. ROWE

____________________________________

Jacob L. Rowe

Case 5:10-cv-00140-C Document 56 Filed 05/02/12 Page 3 of 3