Hernandez v. Global Prisoner Services, LLC D/b/a Texas Prisoner Transportation Services

Western District of Texas, txwd-5:2019-cv-00374

MOTION to Withdraw as Attorney for Bridget Davidson by Amanda Hernandez.

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION AMANDA HERNANDEZ, § Individually and On Behalf of All § Others Similarly Situated, § § Plaintiff, § No. 5:19-cv-00374-FB § v. § § GLOBAL PRISONER SERVICES, § LLC d/b/a TEXAS PRISONER § TRANSPORTATION SERVICES, § § Defendants. § PLAINTIFF'S MOTION TO WITHDRAW AS COUNSEL Plaintiff Amanda Hernandez, Individually and on behalf of all others similarly situated ("Plaintiff") files this Motion to Withdraw Bridget Dale Davidson as Counsel. In support thereof, Plaintiff respectfully submit the following: The attorneys of record for Plaintiff are Melissa Moore and Curt Hesse. Plaintiff moves to withdraw Bridget Dale Davidson from Moore & Associates as counsel in this matter. Bridget Dale Davidson is no longer employed by Moore & Associates. Melissa Moore and Curt Hesse of Moore & Associates will remain attorney of record for Plaintiff, and therefore, should continue to receive all notices, filings, and correspondence in this action. This Motion to Withdraw as Counsel is not for the purpose of delay and will not prejudice the rights of the parties to this litigation. The undersigned respectfully requests that al counsel of record, parties and this court tame proper notice of this appearance and continue to forward all appropriate filings, notices, or other correspondence to Melissa Moore and Curt Hesse at the contact address noted below. WHEREFORE, Plaintiff respectfully request the Court to grant this Motion to Withdraw as Counsel. Respectfully submitted, MOORE & ASSOCIATES By: Melissa Moore State Bar No. 24013189 Federal Id. No. 25122 Curt Hesse State Bar No. 24065414 Federal Id. No. 968465 Lyric Center 440 Louisiana Street, Suite 675 Houston, Texas 77002 Telephone: (713) 222-6775 Facsimile: (713) 222-6739 ATTORNEYS FOR PLAINTIFF -2- CERTIFICATE OF SERVICE As required by Fed. R. Civ. P. 5(a)(1), I certify that I served this document on all parties or their attorney(s) of record—who are listed below—in accordance with Fed. R. Civ. P. 5(b) as follows: Global Prisoner Services, LLC d/b/a Texas Prisoner Transportation Services c/o Thor Catalogne 108 E. Highway 79 Thrall, Texas 76578 mail personal delivery leaving it at office dwelling leaving it with court clerk electronic means other means CM/ECF system PTS of America, LLC c/o Davidson Corporate Services, Inc. 511 Union St., Ste. 1600 Nashville, TN 37219-1780 mail personal delivery leaving it at office dwelling leaving it with court clerk electronic means other means CM/ECF system -3- Ryan Whitten 1854 Air Lane Dr., Ste. 20 Nashville, TN 37210 mail personal delivery leaving it at office dwelling leaving it with court clerk electronic means other means CM/ECF system October 29, 2019 Date Melissa Moore -4-