8 FILE CAUSE NO. GN103254 —— RICHARD KLUGMAN 8 INTHE DISTRICT COURT OF § . § 8 INTERNATIONAL GLOBAL 5 POSITIONING, INC. D/B/A IGP, 5 TRAVIS COUNTY, TEXAS JOHN J. MADSEN, AND 5 DWIGHT JORY § § BOBBY SARGENT 5 20ST JUDICIAL, DISTRICT MOTION To WITHDRAW aS COUNSEL, COME NOW, Raymond 5. White, W. Brewster McCracken and Akin Gump Strauss Hauer ater ol & Fold LLP (h ectively referred to a5 “Akin Gump") and move the Cour to permit them to withdraw as counsel for Intemational Global Po: ioning, Ine. bla 1GP, DefendanCounter-Plaintiff Third-Party Plaintiff, Defendam John J. Madsen, and Defendant ‘Dwight Jory, and would show the Court as follows: 1. Thereis good cause as required by Rule 10 af the Texas Rules of C Procedure for this Court to grant this metion becanse Defendants have failed to pay Akin Gump for its services for rani this and other matters. 2. Akin Gump tas delivered this Motion to International Globel Positioning, ie. 2/2 IGP by hand delivery, facsimile, regular mail, and certified mail; to Joha J. Madsen by band delivery, facsimile, regular mail, and certified mail; and to Dwight lory by facsimile, regular mail, and certified mail. Movants have notified Defendants of their right to object to this motion, Intemational Global Positioning, Ine. d/b/a IGP and John Madsen have not indicated whether they consent to this notion. Dwight Jory does not consent to this motion, PLAINTIFF'S: EXHIBITJs ea onsan6z90 AKIN Gee woo. 005 3. Plaintiff does not oppose this motion 4. ‘The last known address for Inemationat Global Positioning, Ine. W/e/a IGP and for John J. Madsen is 720 Brazos Steet, Suite 500, Austin, Texas 78701, telephione 512-334-39: facsimile $12-354-5975. The last known address for Defendant Dwight Jory is 2050 West ‘Warmsprings, No. 3324, Henderson, Nevada 85014, tlephone 702-277-3165, facsimile 702-898- 03s. 5. The only pending setting or deaciine im this case of which movants are aware is the hearing on Plaintif’s Motion to Enter Judgment Pursuant to Rule 11 Agreement scheduled for 9:00 ‘am. on January 22, 2003, and the hearing on this motion, scheduled for the same date and time. WHEREFORE, PREMISES CONSIDERED, Raymond =. White, W. Brewster MoCracken , and Akin Gump Strauss Hauer & Feld LLP pray that the Court grant this Metios and'order that movants are withdrawn as counsel of record (or and have no further obligations to represent Intemational Gigbal Positioning, Inc. dib/a IGP, John J. Madsen, and Dwight Jory in ey may deemed justly any capacity. Movants pray for such other and further relief to which th entitled Respeotflly submitted, AKIN GUMP STRAUSS HAUER & FELD By CA Lee Rayinond & White State Bar No. 21321950 300 West Sixth Strest, Suite 2100 ‘Avstin, Texas 78701 (512) 499-6200 (512) 499.6290 ~ Fax ATTORNEYS FOR DEFENDANTS! COUNTERPLAINTIFF/THIRD-PARTY PLAINTIFF fesse MUSTO Tt