MOTION FOR WITHDRAWAL OF PLAINTIFFS' COUNSEL. Plaintiffs JAMES MCGIBNEY and VIA VIEW, INC., (Plaintiffs), brings this

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1 No JAMES MCGIBNEY AND VIA VIEW, INC. vs. THOMAS RETZLAFF, LORA LUSHER, JENNIFER D'ALESSANDRO, NEAL RAUHAUSER, MISSANONNEWS, JANE DoE 1, JANE DoE 2, JANE DOE 3, JANE DOE 4 AND JANE DOE 5 IN THE DISTRICT COURT OF, TEXAS 67TH JUDICIAL DISTRICT MOTION FOR WITHDRAWAL OF PLAINTIFFS' COUNSEL TO THE HONORABLE JUDGE OF SAID COURT: Movants, JOHN 8. MORGAN and the MORGANLAWFIRM, Attorneys for Plaintiffs JAMES MCGIBNEY and VIA VIEW, INC., (Plaintiffs), brings this Motion for Withdrawal of Counsel, and in support shows the Court the following: 1. This motion is based on good cause in that irreconcilable differences have arisen between client James McGibney and his attorney. Current counsel does not wish to set forth these irreconcilable differences within this pleading, because the Undersigned is concerned disclosure of this information could be potentially harmful to the Plaintiffs as they pursue this cause of action. In addition to irreconcilable differences, Plaintiffs and the Undersigned are not in agreement with regard to the payment of

2 attorneys' fees and expenses necessary for the prosecution of this c1~twb\~~~ copy of this Motion, the Undersigned is complying with Rule 10 by informing Plaintiffs and the Court that there are no settings or deadlines of which the Undersigned is aware, with the exception of the deadline of thirty (30) days from March 18, 2014, for responding to Rauhauser's Requests for Disclosures, which such deadline is April17, This is a brand new case, there is no Docket Control Order, no trial settings, and therefore the withdrawal of the Undersigned cannot cause any harm or prejudice to Plaintiffs who will have ample time to seek new counsel. 2. The Undersigned has provided to Plaintiffs this day a copy of Neal Rauhauser's pleadings, which include his Verified Special Appearance pursuant to Tex. R. Civ. P. 120(a), Original Answer Subject to a Special Appearance, Counterclaims, Jury Demand, and Requests for Disclosure. As such, this withdrawal is not sought for delay. 3. A copy of this motion has been delivered to Plaintiffs James McGibney and Via View, Inc. at their current address, Cheaterville, Southern Highlands Parkway, # , Las Vegas, NV 89141, (702) , via certified mail, and through . Plaintiffs have been notified in writing of their right to object to this Motion for Withdrawal.

3 4. Undersigned attorneys request this Court set this Mo1!:tb~T~6L&~~ consideration via submission at the Court's earliest convenience. WHEREFORE PREMISES CONSIDERED, JohnS. Morgan and the Morgan Law Firm, attorneys for Plaintiffs, pray that this Court grant this Motion to Withdraw as counsel of record for Plaintiffs, for such other and further relief, at law or in equity, to which they may be justly entitled. Respectfully submitted, JOHNS. MORGAN Texas Bar No MORGAN LAW FIRM 2175 North Street, Ste. 101 Beaumont, Texas (409) (409) facsimile ATTORNEY FOR PLAINTIFFS

4 CERTIFICATE OF SERVICE Undersigned counsel hereby certifies that a true and correct copy of the foregoing document has been provided to all parties and counsel of record, via facsimile and/or certified mail, return receipt requested on this 19th day of March, 2014: James McGibney Via CM/RRR-# Via View, Inc. Cheaterville Southern Highlands Pkwy., # Las Vegas, NV (702) james@bullyville.com Jeffrey L. Dorell Via facsimile (713) Philip A. Meyer Katy Frwy., Ste. 850 Houston, Texas JOHN MORGAN

5 CERTIFICATE OF LAST KNOWN ADDRESS This will certify the last known address of Plaintiffs are as follows: James McGibney Via View, Inc. Cheaterville Southern Highlands Pkwy., # Las Vegas, NV (702) j ames@bullyville.com JOHN S. MORGAN