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lane L.

Evans
Telephone: (770) 443-4108 Facsimile: (770) 443-9013 e-mail: JLELegal@aol.com mobile: (404) 862-4705

April 8th , 2013


VIA U.S. MAIL

Treva Shelton, Clerk Paulding County Superior Court 280 Constitution Blvd. Room 1028 Dallas, GA 30132

Re: Freeman v. Todd Paulding County Superior Court Civil Action No:12-CV-1077-TB
Dear Ms. Shelton: Enclosed please find the Original and one copy of Ms. Evans' Motion to Withdraw, along with proposed Order Granting Motion to Withdraw in this matter. Please file the Original with the Court and return a file-stamped copy in the provided self-addressed and stamped envelope, and submit the Order to the Judge for his review. If you have any questions, please contact the office at (770) 443-4108. Thank you so much for your assistance in this matter. Yours Truly,

Bianka Luallen Assistant to Jana L. Evans BL Enclosures

355 Camden Woods Dr. Dallas, GA 30157

IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA

GILBERT FREEMAN, JR., Plaintiff,


V S.

CIVIL ACTION FILE NO. 12-CV-1077-TB

JODY EBRIGHT TODD, Defendant.

MOTION FOR WITHDRAWAL OF COUNSEL Comes now Jana L. Evans, counsel of record for Plaintiff herein, and pursuant to Uniform Superior Court Rule 4.3(1), requests that the Court permit her to withdraw from representation of Plaintiff herein, GILBERT FREEMAN, JR. This request is made after the verbal request of Plaintiff herein on March 29 th , 2013, followed by a formal written request on April 6 th , 2013 expressly directing Counsel to withdraw. Counsel has previously notified Plaintiff as follows: (1) Counsel wishes to withdraw from representation of Plaintiff for the following reasons: (2) (3) The Paulding County Superior Court shall retain jurisdiction of this action; Plaintiff, GILBERT FREEMAN, JR., has the burden of keeping the court informed concerning where notices, pleadings or other papers may be served upon him;

(4)

Plaintiff, GILBERT FREEMAN, JR., has the obligation to prepare for trial or to hire other counsel to prepare for trial when the trial date has been set.

(5)

That if Plaintiff, GILBERT FREEMAN, JR., fails or refuses to meet these burdens, Plaintiff may suffer adverse consequences;

(6)

The dates of any scheduled proceedings, including trial, will not be affected by the withdrawal of counsel;

(7)

Service of notices may be made upon Plaintiff, GILBERT FREEMAN, JR., at Plaintiff's last known address:

(8)

This case has not been scheduled for trial, and there is no expectation that the granting of this Motion would result in a delay of the trial of this matter.
CONCLUSION

WHEREFORE, Plaintiff's counsel urges the Court to grant her motion to withdraw from this matter. Respectfully submitted this 8 th day of April, 2013.

LAW OFFICE OF JANA L. EVANS 355 Camden Woods Drive Dallas, GA 30157 (770) 443-4108 e-mail: jlelegal@aol.com ara L. Evans d Bar No. 200090

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IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA

GILBERT FREEMAN, JR., Plaintiff, vs. JODY EBRIGHT TODD, Defendant. CIVIL ACTION FILE NO. 12-CV-1077-TB

CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing Plaintiff's Counsel's Motion for Withdrawal, by placing the same in the United States Mail addressed to Plaintiff and Defendant's counsel, postage prepaid, as follows:

Parisa N. Herrin, Esq. The Herrin Law Firm, PC 19 Trammell Street Marietta, GA 30064

Gilbert Freeman, Jr.

Angela Woodall 162 Main Street


Hiram, GA 30141

This 8 th day of April, 2013.

L EVANS ar No. 200090 355 Camden Woods Drive Dallas, GA 30157 phone (770) 443-4108 e-mail: jlelegal@aol.com AND jlelegal2aol.com

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IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA

GILBERT FREEMAN, JR., Plaintiff,


VS.

CIVIL ACTION FILE NO. 12-CV-1077-TB

JODY EBRIGHT TODD, Defendant.

ORDER GRANTING MOTION FOR WITHDRAWAL OF COUNSEL


Plaintiff's Counsel's Motion for Withdrawal of Counsel having been read and considered, and Plaintiff's counsel having properly complied with Superior Court Rule 4.3 and good cause having otherwise been shown. IT IS HEREBY ORDERED that said Motion is GRANTED. Plaintiff's Counsel, Jana L. Evans, is permitted to withdraw from representation of Plaintiff in this matter. Ms. Evans' withdrawal will be effective ten (10) days from the date of this Order or upon the entry of a Notice of Appearance by Plaintiff's new counsel, whichever is sooner. SO ORDERED this

2nd day of May

, 2013.

TONNY S. BEAVERS, Chief Judge, Paulding County Superior Court

Presented by:

a L. Evans, Ga Bar No. 200090


amden Woods Drive as, GA 30132 (770) 443-4108 e-mail: ilelecialaol.com AND jlelegal2aol.com