FILED

DALLAS COUNTY
9/21/2016 3:51:32 PM
FELICIA PITRE
DISTRICT CLERK

Case No. DC-15-12368

JSJ INVESTMENTS INC.

IN THE DISTRICT COURT

Vs.

162ND DISTRICT COURT

HANNOVER HOUSE INC.

DALLAS COUNTY, TEXAS

DEFENDANTS COUNSELS MOTION TO WITHDRAW

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, James Carroll, counsel for Defendant, Hannover House Inc. and files this
motion to withdraw and in support would show the Court as follows.
I.
Defendant Hannover House Inc. and its counsel have had a disagreement about this case
that renders it impossible for Counsel James Carroll to continue representing Defendant. This
withdrawal is necessary as a conflict has arisen between Plaintiff and counsel in this case that
defeats the purpose of the attorney client relationship. Counsel cannot continue to represent
Plaintiff in this case. Plaintiff has been asked to agree to the withdrawal from this case but has
not at this time agreed to this request.
II.
Counsel James Carroll has sent the letter attached to this motion to Defendant, Hannover
House Inc., as required by the Collin County Local Rules. This letter has been sent by regular
mail and email to Defendant at its last known address of 1428 Chester Springdale Arkansas
72764. The letter advises Defendant Hannover House that James Carroll will be seeking to
withdraw from representation of Hannover House Inc. in this case. It advises Hannover House
Inc that the motion will be presented to the Court not less than 10 days from this date. It also

JamesCarrollCounselforDefendantHannoverHouseInc.MotiontoWithdraw
1

Page1

advises Hannover House Inc that any objection to this request to withdraw should be made in
writing with the Court as soon as possible.
III.
Counsel James Carroll believes that he has complied with the Dallas County local rules
with regard to the requirements needed to be allowed to withdraw from representation of
Defendant Hannover House Inc in this case. Counsel requests that this motion be set for a
hearing and that the Court sign an order that provides for the withdrawal of James Carroll as
counsel for Hannover House Inc in this case.
Wherefore, premises considered, James Carroll requests that this motion be set for
hearing and that the Court grant the motion to withdraw and for such other and further relief to
which he may be entitled.
Respectfully Submitted,
_/s/ James B. Carroll______________
James Brendan Carroll III
501 Elm St # 385
Dallas Texas 75202
Telephone 214-760-7788
Facsimile 214-540-1210
Email: james.carroll123@sbcglobal.net
State Bar Card # 03886700
Attorney for Plaintiff
Certificate of Service
A copy of this motion will be served upon opposing counsel for Plaintiff on this the 21st
day of September, 2016 by email. A copy will also be emailed to the several email addresses that
counsel has for Hannover House Inc.
_/s/ James B. Carroll______________
James Brendan Carroll III

JamesCarrollCounselforDefendantHannoverHouseInc.MotiontoWithdraw
2

Page2

CERTIFICATE OF CONFERENCE
I have not yet spoken to opposing counsel regarding the subject of this motion and
whether he would oppose my withdrawal. I have placed several calls and emails to him and am
awaiting his reply. I will advise the Court if I hear from either opposing counsel or the client in
this case that they agree to the entry of the withdrawal order. Counsel for the Plaintiff does not
object to my withdrawal.
_/s/ James B. Carroll______________
James Brendan Carroll III

JamesCarrollCounselforDefendantHannoverHouseInc.MotiontoWithdraw
3

Page3

JAMES BRENDAN CARROLL III

Attorney and Counselor at Law
501 Elm Street Suite 385, L.B. 33
Dallas, Texas 75202
Telephone 214-760-7788
Facsimile 214-540-1210
September 21, 2016

HANNOVER HOUSE INC

1428 CHESTER
SPRINGDALE, AR 72764
RE:

DC-15-12368 HSJ INVESTMENTS INC. v. HANNOVER HOUSE, INC.

Our File Number: 1515433.00

Dear Sir:
I need to withdraw from your case. I have communicated my reasons to
do so in my phone messages to your office. I will be filing the attached
motion to withdraw today. There is a summary judgment hearing set for
September 26 at 1:30 PM and a trial set on October 20 2016. There is
also a mediation order in the case that will require you to go to
mediation. Let me know if you will agree to sign off on my withdrawal
order in this case. The Court will consider this motion within 10 days of
todays date. Let me Court know if you have an issue with the Court
allowing me to withdraw from the case as your attorney.
Should you have any questions or comments with regard to this
matter, please do not hesitate to contact us.

Sincerely,

/s/ James B. Carroll

James B. Carroll III

JBC/dc