Motion to Withdraw as Legal Counsel of Defendant
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Motion by Prime Prep Academy's attorneys to withdraw from charter revocation case.
Transcript of Motion to Withdraw as Legal Counsel of Defendant
S.O.A.H. DOCKET N04 701-14-5126 TEXAS EDUCATION ASSOCIATION BEFORE THE
Petitioner, STATE OFFICE
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ADMINISTRATIVE UPLIFT FORT WORTH, CDC d/IJ/a HEARINGS PRIME PREP ACADEMY
Respondent.
MOTION TO WITHDRAW AS LEGAL COUNSEL OF DEFENDANT TO THE STATE OFFICE OF ADMINSTRIATIVE HEARINGS:
COMES NOW, the undersigned legal counsel in the above styled matter and hereby files this Motion to Withdraw as legal counsel and attomey ofreeord for the Respondent, in the above
styled matter‘
In suppon thereofcounsel shows the following:
14 Respondent’s attorney has been unable to communicate with Respondent
regarding either Respondent’s position to the upcoming hearing or regarding payment
for services rendered on behalf of the Respondent. Respondent’s account is seriously
delinquent.
2. Respondent’s attomey will send this motion to Respondent by certified mail and
email.
3. Attached to this Motion is Notice sent Certified Mail to the Respondent stating
this Motion would be presented to the Court.
4. By this motion Respondent shall be made aware that he can object to this motion.
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5. Respondent’s last known address and phone are: Uplift Fort Worth CDC c/0 Prime Prep Academy Dallas, 330 East Ann Arbor, Dallas, TX 75216, 866-933-7065.
This Withdrawal is not sought for delay, there is a pending hearing scheduled for 9:00 am
on January 27, 2015.
PRAYER WHEREFORE PREMISES CONSIDERED, Darren G. Gibson and O’Hanlon
McCollom, & Demerath, respectfully moves to withdraw as attorney for Defendant.
Dated: January 22, 2015 Respectfully submitted,
/s/ Darren G. Gibson DARREN G. GIBSON State Bar N0. 24068846 O’I-Ianlon McCollom & Demerath 808 West Avenue Austin, Texas 78701 Tel: (512)494-9949 Fax: (512)494-9919 [email protected]
Atturneysfor Respondent Uplift Fort Worth, CDC
CERTIFICATE OF CONFERENCE
I hereby certify that I attempted to confer with Eric Marin, counsel for Petitioner TEA,
about this motion on January 22, 2015; however I was unable to reach Mr, Marin. Due to the
impending hearing scheduled for January 27, 2015, I am filing this motion prior to receiving a
response from Mr. Marin, regarding the TEA’s response to this motion.
/s/ Darren G. Gibson Darren G. Gibson
MOTION TO WITHDRAW DOCKET Nu. 407-ll-4167 PAGE 1 OF 4
CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing MOTION TO WITI-IDRAW
has been served on January 22, 2015, via facsimile, to the following:
Eric T. Marin Texas Education Association I701 North Congress Avenue Austin, Texas 78701 512-463-9720 512-475-3662 (fax) Counsel for Petitioner
/s/ Darren G. Gibson Darren G. Gibson
MOTION T0 WITHDRAW DOCKET NO. 701-145126 PAGE 3 OF 4
S.O.A.H. DOCKET NO. 701-14-5126 TEXAS EDUCATION ASSOCIATION BEFORE THE
Petitioner, STATE OFFICE
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ADMINISTRATIVE UPLIFT FORT WORTH, CDC d/b/2 HEARINGS PRIME PREP ACADEMY
Respondent.
ORDER GRANTING MOTION TO WITHDRAW On , 2015, came on to be considered Motion to Withdraw in
the above-styled and numbered cause of action, and the State Office of Administrative Hearings
having considered the Motion is of the opinion that the same should be granted;
IT IS THEREFORE, ORDERED, ADJUDGED AND DECREED by the Court that Darren G. Gibson of the Law Office of O’I-Ianlon McCo||0m & Demerath be withdrawn as attomeys of record for Uplift Fort Worth CDC d/b/a PRIME PREP ACADEMY and said motion is hereby
(Granted) (Denied)
SIGNED this _day oflanuary, 2015.
HEARING OFFICER
MOTION TO WITHDRAW DOCKET Nu. 407-ll-4167 PAGE A OF 4
