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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

PENSACOLA DIVISION 

UNITED STATES OF AMERICA 

 ex rel, Robert V. Smith 

 Qui Tam Plaintiff, 

v. Civil Action No. 3:20cv3678-MCR-ZCB 

 

JAY A. ODOM; OKALOOSA 

COUNTY, BOARD OF 

COUNTY COMMISSIONERS; 

 Defendants. 

__________________________________________________________________ 

MICHAEL J. SCHOFIELD AND CLARK PARTINGTON’S 

MOTION TO WITHDRAW AS COUNSEL 

 Michael J. Schofield and Clark Partington, pursuant to Local Rule 

11.1(H)(1)(b), hereby move this Court to withdraw as counsel for Plaintiff, ROBERT 

V. SMITH, and state: 

1. Undersigned counsel, Michael J. Schofield, and the Clark Partington 

Law Firm, have been excused from the representation of Plaintiff, ROBERT V. 

SMITH (hereafter “Smith”), in this action. 

2. Smith has been and will continue to be represented by the following 

counsel: 

a. Amelia Hallenberg Beard, formerly with the Clark Partington Law 

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Firm, currently with the Moorhead Law Group, is an attorney of record on Smith’s 

behalf and intends to continue in the case. 

b. Elizabeth Clements Billhimer resigned from the Clark Partington 

Law Firm effective March 31, 2024. 

c. On April 17, 2024, Smith elected in writing to have his files 

transferred to and remain with Elizabeth Clements Billhimer at her new law firm. Ms. 

Billhimer is an attorney of record and she intends to continue in the case. 

d. Undersigned was the third attorney on the matter for Smith and is 

no longer needed for the prosecution of this case. 

3. As stated above, Smith has consented to the relief sought in this motion 

as shown by his Directive of Continuing Representation. 

4. Counsel for Defendant Jay A. Odom, Ben Gordon of Anchors Gordon, 

and Nathaniel H. Hunt of Kaplan Kirsch, have consented to the relief sought in this 

motion. 

5. Counsel for Defendant Okaloosa County Board of County 

Commissioners, Gregory Stewart of Nabors Giblin & Nickerson, did not respond to 

repeated requests for consent to the relief sought in this motion. 

6. The withdrawal will not cause the continuance of any trial, hearing or 

other court proceeding. 

WHEREFORE, Michael J. Schofield and Clark Partington respectfully 

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request this Court enter an order allowing their withdrawal as counsel for Plaintiff, 

ROBERT V. SMITH, in this action and granting such other relief as the Court deems 

appropriate. 

 Respectfully submitted, 

/s/ Michael J. Schofield 

MICHAEL J. SCHOFIELD 

Florida Bar Number: 373656 

CLARK PARTINGTON 

 125 E. Intendencia St. 

Pensacola, Florida 32502 

(850) 434-9200; (850) 432-7340 facsimile 

P/E: mschofield@clarkpartington.com

S/E: ahallecy@clarkpartington.com

S/E: ttorrez@clarkpartington.com 

 

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CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the foregoing has been 

electronically filed via the Court’s CM/ECF system and served electronically to all 

counsel of record listed below, this 4th day of June, 2024. 

DAVID M. SOBOTKIN 

David.m.sobotkin@usdoj.gov 

ATTORNEY FOR PLAINTIFF 

UNITED STATES OF AMERICA 

AMELIA H. BEARD 

abeard@moorheadlaw.com

ATTORNEY FOR PLAINTIFF 

ROBERT V. SMITH 

ELIZABETH CLEMENTS BILLHIMER 

ebillhimer@destinlaw.com

ATTORNEY FOR PLAINTIFF 

ROBERT V. SMITH 

CHRISTOPHER A. KNIGHT 

Christopher.knight@myfloridalegal.com

ATTORNEY FOR PLAINTIFF 

STATE OF FLORIDA 

A. BENJAMIN GORDON, III 

bgordon@anchorsgordon.com

ANNE NICOLE IZZO 

aizzo@anchorsgordon.com 

ATTORNEY FOR DEFENDANT 

JAY A. ODOM 

 

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NATHANIEL HEMMERICK HUNT 

nhunt@kaplankirsch.com

PETER J. KIRSCH 

pkirsch@kaplankirsch.com

SARAH WILBANKS 

swilbanks@kaplankirsch.com 

ATTORNEY FOR DEFENDANT 

JAY A. ODOM 

GREGORY T. STEWART 

gstewart@ngn-tally.com

KERRY ANNE PARSONS 

kparsons@ngnlaw.com

LYNN MIYAMOTO HOSHIHARA 

lhoshihara@ngnlaw.com

MATTHEW R. SHAUD 

mshaud@ngnlaw.com 

ATTORNEY FOR DEFENDANT 

OKALOOSA COUNTY BOARD 

OF COUNTY COMMISSIONERS 

 /s/ Michael J. Schofield 

 MICHAEL J. SCHOFIELD 

 

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