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IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MISSOURI

THEODORE E. WRIGHT, III, et al.,


vs.

DEUTSCHE BANK NATIONAL TRUST
COMPANY, et al.,

Plaintiffs,








Case No. 3:12-CV-05120-GAF

Defendants.

MOTION TO WITHDRAW AS ATTORNEY OF RECORD

COME NOW Donald M. Brown, K. Patrick Douglas, Nathan A. Duncan and the law
firm of Douglas, Haun & Heidemann, P.C., Attorney of Record for Plaintiffs, Theodore E.
Wright, II and Sherry O’Neal-Wright, and respectfully request leave of the Court to withdraw as
Plaintiff’s counsel. In support of this motion, counsel states:

1. Attorneys, Donald M. Brown, K. Patrick Douglas, and Nathan A. Duncan, of the firm of

Douglas, Haun & Heidemann, P.C. are the attorneys of record for Plaintiffs herein.

2. Counsel is mindful of the Court’s reluctance to grant such motions where there is no

assurance of an entry of appearance by substitute counsel. See, L.R. 83.5(o).

3. However, there are grounds to withdraw as Attorney of Record for Plaintiffs in this action
under the Rule 4-1.16(b) of the Missouri Rules of Professional Conduct. Such grounds are
protected by the attorney-client privilege. Such grounds may be disclosed to the court, ex
parte, should the Court so require in order to rule upon the merits of this motion.

WHEREFORE, Donald M. Brown, K. Patrick Douglas, Nathan A. Duncan and the law
firm of Douglas, Haun & Heidemann, P.C., request an Order of this Court granting leave to
withdraw as Attorney of Record for Plaintiffs and for such other relief as the Court deems just and
proper.

DOUGLAS, HAUN & HEIDEMANN, P.C.
111 West Broadway, P.O. Box 117
Bolivar, Missouri 65613
Telephone: (417) 326-5261
Fax: (417) 326-2845
[email protected]


By___/s/ Nathan A. Duncan________________________

Nathan A. Duncan
Missouri Bar No. 60186

Case 3:12-cv-05120-GAF Document 67 Filed 02/18/14 Page 1 of 2



CERTIFICATE OF SERVICE





I hereby certify that on February 18, 2014, I electronically filed the foregoing with the



Clerk of the Court using the CM/ECF system which sent notification of such filing to all counsel
of record. A copy of the foregoing was served on Plaintiff by first-class mail on February 18,
2014.


DOUGLAS, HAUN & HEIDEMANN, P.C.

By /s/ Nathan A. Duncan___________________

Case 3:12-cv-05120-GAF Document 67 Filed 02/18/14 Page 2 of 2