ACCEPTED
05-15-00644-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
11/17/2015 4:25:20 PM
LISA MATZ
CLERK
No. 05-15-00644-CV
FILED IN
In the 5th COURT OF APPEALS
DALLAS, TEXAS
Court of Rppeato 11/17/2015 4:25:20 PM
LISA MATZ
Clerk
jfiftb rittitritt of Eexa5 at ;3atia5
JOHN YI,
Appellant
v.
BONG KO
Appellee
On Appeal from the 101st Judicial District Court, Dallas Count, Texas
Cause No. DC-13-10821
APPELLANT'S UNOPPOSED MOTION FOR WITHDRAWAL AND
SUBSTITUTION OF COUNSEL
John Franklin Guild
jguild@ghjhlaw.com
State Bar No. 24041022
Gruber Hurst Elrod Johansen Hail Shank LLP
1445 Ross Avenue, Suite 2500
Dallas, Texas 75202
Telephone No. (214) 855-6800
Facsimile No. (214) 855-6808
ATTORNEYS FOR APPELLANT
1
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW the Appellant, and files this Motion For Withdrawal and
Substitution of Counsel, and in support thereof respectfully states:
1. Appellant is currently represented by James H. Bilton, W. Scott
Hasting, and the law firm of Locke Lord LLP as counsel of record for Appellant in
the above-referenced matter.
2. Appellant has recently engaged John Franklin Guild of Gruber Hurst
Elrod Johansen Hail Shank LLP to serve as counsel in this matter.
3. Appellant desires and consent to substitute John Franklin Guild and
the law firm of Gruber Hurst Elrod Johansen Hail Shank LLP in place of James H.
Bilton, W. Scott Hasting, and the law firm of Locke Lord LLP as counsel of record
for Appellant in the above-referenced matter.
4. Appellant requests that all notices and pleadings in this case be
directed to:
John Franklin Guild
State Bar No. 24041022
jguild@ghjhlaw.corn
Gruber Hurst Elrod Johansen Hail Shank LLP
1445 Ross Avenue, Suite 2500
Dallas, TX 75202-2711
Telephone (214) 855-6800
Facsimile (214) 855-6808
5. Appellant approves this substitution of counsel.
2
6. Substitution should not affect any scheduling related to this matter.
This Court issued is Memorandum Opinion dismissing the appeal for want of
jurisdiction on September 29, 2015, but Mandate has not yet issued. The
withdrawal and substitution is not sought for purposes of delay, but so that justice
may be done.
7. The undersigned counsel conferred with counsel for Appellee
concerning the relief sought in this motion. Counsel for Appellee stated that
Appellee is unopposed to the motion.
WHEREFORE, PREMISES CONSIDERED, Appellant, moves that John
Franklin Guild of Gruber Hurst Elrod Johansen Hail Shank LLP be substituted in
as counsel for Appellant.
Respectfully submitted,
/s/ John Franklin Guild
Michael K. Hurst
mhurst@ghjhlaw.com
State Bar No. 10316310
John Franklin Guild
jguild@ghjhlaw.com
State Bar No. 24041022
Gruber Hurst Johansen Hail Shank LLP
1445 Ross Avenue, Suite 2500
Dallas, Texas 75202
Telephone No. (214) 855-6800
Facsimile No. (214) 855-6808
ATTORNEYS FOR APPELLANT
3
CERTIFICATE OF CONFERENCE
The undersigned counsel conferred with counsel for Appellee concerning the
relief sought in this motion. Counsel for Appellee stated that Appellee is
unopposed to the motion.
/s/ John Franklin Guild
John Franklin Guild
CERTIFICATE OF SERVICE
The undersigned certifies that on this 17th day of November, 2015, a true and
correct copy of the foregoing document has been sent by electronic service to the
following counsel of record:
Tailim Song Michael Weston
Amy Hsu Bennett, Weston, LaJone & Turner PC
13140 Coit Road, Suite 350 1603 LBJ Freeway, Suite 280
Dallas, Texas 75240 Dallas, Texas 75234
Counsel for Plaintiff Bong Ko Counsel for Defendants Kon Young
Park and Unlimited PCS, Inc.
/s/ John Franklin Guild
John Franklin Guild
CERTIFICATE OF COMPLIANCE WITH RULE 9.4
I, John Franklin Guild, attorney for Petitioners certify that this document
was generated by a computer using Microsoft Word 2010 which indicates that the
word count of this document is 291 per TEX. R. APP. P. 9.4 (i).
/s/ John Franklin Guild
John Franklin Guild
4
John Yi v. Bong Ko, Kon Young Park and Unlimited PCS, Inc.
Combined Opinion