`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`Case No. 2:15-CV-1274-JRG-RSP
`LEAD CASE
`
`JURY TRIAL DEMANDED
`
`
`
`BLITZSAFE TEXAS, LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`HONDA MOTOR CO., LTD.; AMERICAN
`HONDA MOTOR CO., INC.; HONDA OF
`AMERICA MANUFACTURING, INC.;
`HONDA MANUFACTURING OF ALABAMA,
`LLC; and HONDA MANUFACTURING OF
`INDIANA, LLC,
`
`
`
`
`
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`
`UNOPPOSED MOTION TO WITHDRAW AS ATTORNEY OF RECORD FOR DEFENDANTS
`TOYOTA MOTOR CORPORATION, TOYOTA MOTOR SALES, U.S.A., INC., TOYOTA
`MOTOR MANUFACTURING, TEXAS, INC., TOYOTA MOTOR MANUFACTURING,
`KENTUCKY, INC., AND TOYOTA MOTOR MANUFACTURING, MISSISSIPPI, INC.
`
`Defendants Toyota Motor Corporation, Toyota Motor Sales, U.S.A., Inc., Toyota Motor
`
`
`
`Manufacturing, Texas, Inc., Toyota Motor Manufacturing, Kentucky, Inc., and Toyota Motor
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`Manufacturing, Mississippi, Inc. (collectively "Toyota") file this motion to withdraw Margaret Welsh as
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`Counsel of Record for Toyota in case Nos. 2:15-cv-01277 and 2:15-cv-01274.
`
`
`
`The withdrawal of Margaret Welsh will not delay this proceeding, and no prejudice will result to
`
`any party. Toyota will continue to be represented by Harry L. Gillam, Jr., J Thad Heartfield, William
`
`Mandir, John Rabena, Brian Shelton, Chandran Iyer, and Fadi Kiblawi.
`
`
`
`The undersigned counsel has conferred with counsel for Plaintiff on this issue and Plaintiff has
`
`no objection to the withdrawal of Margaret Welsh as counsel for Toyota. Toyota consents to the
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`withdrawal of Margaret Welsh as counsel of record in Case Nos. 2:15-cv-01277 and 2:15-cv-01274.
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 392 Filed 01/13/17 Page 2 of 3 PageID #: 29198
`
`
`
`WHEREFORE, Defendant Toyota respectfully requests that this Court grant this Motion to
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`Withdraw in its entirety and enter an Order permitting Margaret Welsh to withdraw from this action as
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`counsel for Defendant Toyota, and that the clerk remove her name from the list of persons authorized to
`
`/s/J. Thad Heartfield
`
`
`
`J Thad Heartfield
`The Heartfield Law Firm
`2195 Dowlen Rd
`Beaumont, TX 77706
`State Bar No. 09346800
`409-866-3318
`Fax: 409-866-5789
`Email: thad@heartfieldlawfirm.com
`
`OF COUNSEL
`
`SUGHRUE MION, PLLC
`William H. Mandir (pro hac vice)
`John F. Rabena (pro hac vice)
`Brian K. Shelton (pro hac vice)
`Fadi N. Kiblawi (pro hac vice)
`Margaret M. Welsh (pro hac vice)
`2100 Pennsylvania Avenue, NW
`Washington, DC 20037
`(202) 293-7600
`
`Attorneys for Toyota Motor
`Corporation, Toyota Motor Sales,
`U.S.A., Inc., Toyota Motor
`Manufacturing, Texas, Inc., Toyota
`Motor Manufacturing, Kentucky,
`Inc., and Toyota Motor
`Manufacturing, Mississippi, Inc.
`
`receive electronic notices in this matter.
`
`
`
`Dated: January 13, 2017
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 392 Filed 01/13/17 Page 3 of 3 PageID #: 29199
`
`
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`
`
`CERTIFICATE OF SERVICE
`
`
`
`I certify that on January 13, 2017, all counsel of record who are deemed to have
`consented to electronic service are being served with a copy of this document via the
`Court’s CM/ECF system. Any other counsel of record will be served in accordance with
`the Federal Rules of Civil Procedure.
`
`
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`
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`
`
`/s/ J. Thad Heartfield
`J. Thad Heartfield
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