William Cullen Champion v. Marilyn Estlow

ACCEPTED 03-14-00016-CV 3729627 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/12/2015 11:45:42 AM JEFFREY D. KYLE CLERK No. 03-14-00016-CV ________________________________________ FILED IN 3rd COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE THIRD DISTRICT OF TEXAS 1/12/2015 11:45:42 AM AUSTIN, TEXAS JEFFREY D. KYLE __________________________________________ Clerk WILLIAM CULLEN CHAMPION Appellant, v. MARILYN ESTLOW Appellee. ______________________________________________ On Appeal from the County Court at Law Number One of Travis County, Texas ________________________________________________ AGREED MOTION FOR LEAVE TO WITHDRAW AND TO SUBSTITUTE COUNSEL ________________________________________________ Bourland Law Firm, P.C. and William Cullen Champion, Appellant herein, file this Agreed Motion for Leave to Withdraw and to Substitute Counsel pursuant to Tex. R. App. P. 6.5 and, in support thereof, respectfully show as follows: MOTION TO WITHDRAW 1. Cindy Olson Bourland, lead counsel for Appellant in this case, has accepted a gubernatorial appointment to this Court and, therefore, will no longer be in a position to represent Appellant in this cause. For this reason, Bourland Law Firm and its attorneys, Cindy Olson Bourland and Anna Eby, request leave to withdraw as counsel in this case. MOTION TO SUBSTITUTE 2. Appellant requests that attorney Anna Eby of Eby Law Firm, PLLC be substituted in as counsel in this case. Ms. Eby’s information is as follows: Address: 1 Chisholm Trail, Suite 150 Round Rock, Texas 78681 Telephone: (512) 508-2396 Facsimile: (512) 477-0154 State Bar No.: 24059707 3. Appellant approves this substitution, which is not sought for delay. Additionally, all parties in this case agree to the relief requested herein. DESIGNATION OF ATTORNEY IN CHARGE 4. Appellant hereby designates Anna Eby of Eby Law Firm, PLLC as its attorney in charge in this matter, pursuant to the requirements of Tex. R. Civ. P. 10. PRAYER WHEREFORE, PREMISES CONSIDERED, Bourland Law Firm, P.C. and William Cullen Champion pray that the Court grant their Agreed Motion for Leave to Withdraw and to Substitute Counsel, and for any other and further relief to which Appellant may be entitled. ii Respectfully submitted, BOURLAND LAW FIRM, P.C. 1 Chisholm Trail, Suite 150 Round Rock, Texas 78681 (512) 477-0100 (512) 477-0154 (facsimile) By:_________________________________ Cindy Olson Bourland State Bar No. 00790343 bourland@bourlandlaw.com Anna Eby State Bar No. 24059707 EBY LAW FIRM, PLLC 1 Chisholm Trail, Suite 150 Round Rock, Texas 78681 Telephone (512) 508-2396 Facsimile (512) 477-0154 eby@bourlandlaw.com (temporary) iii CERTIFICATE OF CONFERENCE I hereby certify that, on January 8, 2015, I conferred with counsel for Appellee via electronic mail regarding this Motion for Leave to Withdraw and to Substitute Counsel. Appellee does not oppose the relief requested. /s/ Anna Eby______________________ Anna Eby CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this document was served on this the 12th day of January, 2015, on the following: Jessica Lobes – via Electronic Mail Dickman Law Offices, PLLC 6440 North Central Expressway, Suite 200 Dallas, Texas 75206 William Champion – via First Class Mail and Certified Mail 1003 Moon Glow Drive Leander, Texas 78641 ____________________________________ Cindy Olson Bourland iv