Smith v. The Abandoned Vessel

Filing 15

MOTION for Robert J. Killeen, Jr. to Withdraw as Attorney by Nathan Smith, filed. Motion Docket Date 10/9/2007. (Attachments: # 1 Proposed Order Granting Motion to Withdraw as Counsel)(Woodward, Wilbourn)

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Smith v. The Abandoned Vessel Doc. 15 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION NATHAN SMITH VS. THE ABANDONED VESSEL, in rem § § § § § CIVIL ACTION NO. 4:07-00784 ADMIRALTY MOTION TO WITHDRAW AS COUNSEL Robert J. Killeen, Jr. asks this court to allow him to withdraw as attorney for Nathan Smith. A. Introduction 1. 2. Plaintiff is Nathan Smith; Intervenor is Marie Sorenson. This case involves a claim based in admiralty and/or the law of finds for title to an abandoned vessel in Refugio County, Texas. 3. The initial scheduling conference is set for October 25, 2007. B. Facts 4. Petitioner Nathan Smith has discharged Robert J. Killeen, Jr. and Killeen & Stern, P.C. from this case and Robert J. Killeen, Jr. has terminated representation pursuant to Nathan Smith's Contract for Legal Services. 5. Robert J. Killeen, Jr. has delivered a copy of this motion to Nathan Smith and has notified him in writing, by both certified and regular mail, of his right to object to the motion. C. Prayer 6. For these reasons, Robert J. Killeen, Jr. asks this court to grant his motion to withdraw. Dockets.Justia.com Respectfully submitted, KILLEEN & STERN, P.C. By: /s/ Robert J. Killeen, Jr Robert J. Killeen, Jr. Attorney-in-Charge Federal Bar No. 12343 Texas Bar No. 11407000 8 Greenway Plaza, Suite 614 Houston, Texas 77046 713/626-5100 - Telephone 713/626-4545 - Facsimile OF COUNSEL: KILLEEN & STERN, P.C. Wilbourn T. Woodward Federal Bar No. 748044 Texas Bar No. 24056562 8 Greenway Plaza, Suite 614 Houston, Texas 77046 713/626-5100 - Telephone 713/626-4545 - Facsimile Robert C. Stern Texas Bar No. 24053637 Federal Bar No. 584037 400 Poydras Street, Suite 1710 New Orleans, Louisiana 70130 504/525-8111 - Telephone 504/680-6080 - Facsimile 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this pleading has been forwarded to all counsel of record. Terry M. Carroll, Jr. Walker, Keeling & Carrol, L.L.P. 210 East Constitution P.O. Box 108 Victoria, Texas 77902-0108 Via E-mail /s/ Robert J. Killeen,Jr. Robert J. Killeen, Jr. 3

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