Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 6/11/2015 5:00:01 PM JEFFREY D. KYLE Clerk NO. 03-14-00148-CV THIRD COURT OF APPEALS 6/11/2015 5:00:01 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-14-00148-CV *1 ACCEPTED [5647136] CLERK IN THE THIRD COURT OF APPEALS AUSTIN, TEXAS MEHMET TURAN ERKAN, Appellant , v.
HABIBE NALAN ERKAN, Appellee . MOTION TO WITHDRAW AS CO-COUNSEL
Matthew Kolodoski, attorney for MEHMET TURAN ERKAN, asks the Court’s permission to withdraw as co-counsel in this appeal.
A. INTRODUCTION 1. Appellant is MERMET TURAN ERKAN; appellee is HABIBE NALAN
ERKAN.
2. Jennifer L. Mathis is presently lead counsel for MERMET TURAN
ERKAN in this appeal. Matthew Kolodoski is presently co-counsel for
MERMET TURAN ERKAN. Jennifer L. Mathis is not withdrawing as counsel
in this case.
3. MERMET TURAN ERKAN has agreed to this motion. *2 B. ARGUMENT & AUTHORITIES 4. The Court may permit an attorney to withdraw as counsel on appeal. Tex.
R. App. P. 6.5.
5. Matthew Kolodoski has accepted a position working at the U.S. District
Court for the Northern District of Texas and is not permitted to represent clients
during his employment at his new job. Jennifer L. Mathis is staying on this case
as lead counsel for MERMET TURAN ERKAN.
6. There are no current deadlines or settings in this case.
7. Matthew Kolodoski sent a copy of this motion to MERMET TURAN
ERKAN. Tex. R. App. P. 6.5(a)(3), (b).
8. Matthew Kolodoski informed MERMET TURAN ERKAN of his right to
object to this motion. Tex. R. App. P. 6.5(a)(4). MERMET TURAN ERKAN
has agreed to this motion.
9. Jennifer L. Mathis will still continue to represent MERMET TURAN
ERKAN on appeal and all correspondence should continue to be sent to her as
lead attorney for MERMET TURAN ERKAN.
C. PRAYER
10. For these reasons, Matthew Kolodoski asks the Court to grant this motion
and permit him to withdraw as co-counsel in this appeal.
Respectfully submitted, Texas Bar Number No. 24081963 matthew@hqattorneys.com M ACKOY H ERNANDEZ Q UALLS B ROWN & Z AHN , LLP 6017 W. Main Street, Second Floor Frisco, Texas 75034 Telephone: (214) 387-9056 Facsimile: (214) 387-4910 *3 CERTIFICATE OF CONFERENCE The undersigned certifies that he tried contacting Habibe Nalan Erkan, who is representing herself pro se on appeal, regarding this motion multiple times on
June 11, 2015. However, the telephone number that the undersigned counsel has
for Ms. Erkan states that the “mailbox is full,” so the undersigned is unable to
leave a telephone message. Moreover, the undersigned further states that he has no
email address for Ms. Erkan.
/s/ Matthew Kolodoski CERTIFICATE OF SERVICE The undersigned hereby certifies that, pursuant to the Texas Rules of
Appellate Procedure, a true and correct copy of the above and foregoing
instrument was mailed to Appellee on June 11, 2015, at the following address:
Habibe Nalan Erkan
8804 Tallwood Drive
Austin, Texas 78759
