ACCEPTED
03-14-00697-CV
3966022
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/30/2015 1:28:10 PM
JEFFREY D. KYLE
CLERK
APPEAL NO. 03-14-00697-CV
FILED IN
3rd COURT OF APPEALS
. PAMELA MBHL, § ON APPEAL FROM AUSTIN, TEXAS
§ 1/30/2015 1:28:10 PM
Appellant, § THE DISTRICT COURT JEFFREY D. KYLE
§ Clerk
vs. § 250TH JUDICIAL DISTRICT
§
DAVID STERN, § TRAVfS COUNTY, TEXAS
§
Appellee. § (Cause No. D-1-GN-14-002071)
APPELLANT'S MOTION FOR WITHDRAWAL
AND SUBSTITUTION OF COUNSEL
Jeffrey S. Kelly and The Kelly Legal Group, PLLC, co\Jnsel of record for Appellant
Pamela Mehl ("Appellant") moves the Comt to gmnt them permission to withdraw as counsel for
Appellant and to substitute Sandra M. Lefler of The Lefler Law Finn as Attomey of Record for
Appellant in this Cause.
I. Movants would show that there Is good cause for this motion in that Appellant has
retained new counsel to represent her in this case and the withilrawal and substitution of counsel
will not res\Jit in any delay. The name and contact information for the attorney to be substituted
as new counsel for Apjlellant is:
Sandra M. Lefler
The Lefler Law Finn
501 South Austin Aven\Je, Suite 1245
Georgetown, Texas 78626
Telephone: 512.863.5658
Facsimile: 866.583.7294
StateBarNo.l21610•10
Pamela Jv!ehl, Appellantv. Dm•ld Stem, Appellee -Appeal No. 03-·14-00697-CV [on appeal
fi·om Cause· No. D-1-GN-14-002071 (Travis County, 250 111 Judicial Distl'ict Comt, Texasl-
APPELLANT'S MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL
Page 1
2. Movants would show that this Motion has the approval of the client, and that the
withdrawal and substitution are not sought fo1· pmposes of delay only.
WHEREFORE, PREMISES CONSIDERED, Movants pray that this Court grant this
motion and enter its order allowing Jeftl'ey S. Kelly and TJ1e Kelly Legal Group, PLLC lo
withdraw and Sandm M. Lefler to substitute as new counsel for Appellant; and that the Court
grant Appellant and Movanls such other and :f\!rtheJ' relief to whioh they may be justly entitled.
Respectfully submitted,
THE KELLY LEGAL GROUP, PLLC
POBOX2125
Pamela Meh/, Appellant v. David Stem, Appellee- Appeal No. 03-14-00697-CV [on appeal
from Cause No. D-1-GN-14-002071 (Travis County, 250111 Judicial District Court, Texas] -
APPELLANT'S MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL
Page :2
CONSENT OF CLIENT AND SUBS'l'l1'UTE COUNSEL
The \Jildersigned, Pamela Melli, Appellant herein, consents to the withdrawal of Jeffrey
S. Kelly and The Kelly Legal Group, PLLC atl(! the appointment of Sandra M. Lefler of The
Lefler Law Firm as Attomey of Record, and both Appellant and Sandra M. Lefler agree that
substitution of coUtisel in this cause shall not be used as grounds for a continuance.
PAMELA lvfEHL
THE LEFLER LAW FIRM
. Le , SBN 12161040
5l'li"-'Hm'TH AUSTIN A VENUE, SUJTE 1245
0EOROBTOWN, TEXAS 78626
TBLIJPHONH: 512.863,5658
FACSIMILIJ: 866.583.7294
ATTORNEY FOR MOVANT I APPELLANT
Pamela Melt/, Appellant 1'. Dm•Jd Stern, Appellee ~ Appeal No. 03-14-00697-CV [on appeal
from Cm1se No. D-1-GN-14-002071 (Travis County, 2501" Judicial District Court, Texas] ~
APPELLANT'S MOTION FOR WITHDRAWAL AND SUBSTITU'l'ION OF COUNSEL
Pagc3
CERTIFICATE OF CONFERENCE
I hereby certify that I made the following attempts to contact Brent A. Devere, counsel
for Appellee, to confer about the merits of this matter:
1. On January 23, 2015 ~ tele]Jhone call to Brent A. Devere, as well as an email sent to
him at .Qdevcre@141 I west. com, together with a copy of this JJroposed Motion.
Co1msel for Plaintiff advises that l1~peseSJ~n.
FLER LAW FlRI\1
By~iL§~
' ndr . Lefl r 'BN 12161040
501 SOUTH AUSTIN A VENUE, SUITE 1245
GEORGETOWN, TEXAS 78626
TELEPHONE! 512,863.5658
FACSIMIL!l: 866.583.7294
ATTORNEY FOR APPELLANf
Pamela lvMII, Appella/1/ v. Dcll'!d Stem, Appellee~ Appeal No. 03-14-00697-CV [on aj)jleal
from Cause No. D-1-GN-14-002071 (Travis County, 250'" Judicial Distdct Court, Texas] ~
APPELLANT'S MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL
Fagc•l
CERTIFICATE OF SERVICE
I certify that on this this 2 8 day of January, 2015, a tme and coJ1'ect copy of the above
and foregoing APPELLANT'S MOTION FOR WlTHDRAWALAND SUBSTITUTION OF
COUNSEL has been served upon the following attorneys of record in accordance witlt the Texas
Rules of Appellate Procedure to:
Mr. Brent A. Devere
1411 West Avenue, Suite 200
Austin, Texas 78701
Facsimile: 512-457-8060
Attomey ofRccord for Appelle
Pamela Mehl, Appelfantv. Dm•ld Stem, Appellee- Appeal No. 03-14-00697-CV [on appeal
from Cause No. D-l·GN-14-002071 (Travis County, 250'1' Judicial Distlict Comt, Texas] -
APPELLANT'S MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL
Pnge5
APPEAL NO. 03-14-00697-CV
PAMELA MEHL, § ON APPEAL FROM
§
Appellant, § THE DISTRICT COURT
§
vs. § 250m JUDICIAL DISTRICT
§
DAVID STERN, § TRAVIS COUNTY, TEXAS
§
Appellee. § (Cause No. D-1-GN-14-002071)
ORDER PERMITTING WITHDRAWAL OF COUNSEL
AND SUBSTITUTING NEW ATTORNEY IN CHARGE
On this day the motion of JeffreyS. Kelly for leave to withdraw as attorney in charge for
Appellant Pamela Mehl in the captioned case came on for consideration. The Court is of the
opinion that the motion should be granted.
IT IS, THEREFORE, ORDERED that Jeffrey S. Kelly be permitted to withdraw as
attorney for Appellant Pamela Mehl in this cause.
IT IS FURTHER ORDERED that Sandra M. Lefler and The Lefler Law Firm be
substituted as attorney for Appellant Pamela Mehl in this cause. The attorney's address,
telephone and fax numbers, and State Bar identification number are as follows:
Sandra M. Lefler,
Tex. SBN 12161040
The Lefler Law Firm
50 I South Austin Avenue,
Suite 1245
Georgetown, Texas 78626
Tel: 512-863-5658
Fax: 866-583-7294
Email: slefler@leflerlegal.com
Pamela Mehl, Appellant v. David Stem, Appellee -Appeal No. 03-14-00697-CV [on appeal
from Cause No. D-1-GN-14-002071 (Travis County, 2501" Judicial District Comi, Texas] -
APPELLANT'S MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL
Page I
All patiies to this cause are hereby notified that Sandra M. Lefler and The Lefler Law
Finn is now attorney in charge for Appellant Pamela Mehl.
SIGNED on the __ day of _ _ _ _ _ _, 2015.
JUDGE PRESIDING
Pamela Mehl, Appellant v. David Stern, Appellee -Appeal No. 03-14-00697-CV [on appeal
from Cause No. D-1-GN-14-002071 (Travis County, 2501h Judicial District Comi, Texas] -
APPELLANT'S MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL
Page2