ACCEPTED
04-14-00569-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
5/14/2015 1:24:23 PM
KEITH HOTTLE
CLERK
NO. 04-14-00569-CV
FILED IN
4th COURT OF APPEALS
IN THE COURT OF APPEALS SAN ANTONIO, TEXAS
05/14/2015 1:24:23 PM
FOR THE FOURTH DISTRICT OF TEXAS KEITH E. HOTTLE
Clerk
AT SAN ANTONIO
BURTON KAHN,
Appellant,
v.
HELVETIA ASSET RECOVERY, INC.,
Appellee.
HAYNES AND BOONE, LLP’S UNOPPOSED MOTION FOR
LEAVE TO WITHDRAW AS COUNSEL OF RECORD FOR APPELLEE
HELVETIA ASSET RECOVERY, INC.
TO THE HONORABLE COURT OF APPEALS:
In accordance with Rule 6.5 of the Texas Rules of Appellate Procedure,
Haynes and Boone, LLP, Werner A. Powers, and Lisa S. Barkley (collectively
“Haynes and Boone”) file this Unopposed Motion to Withdraw as Counsel of
Record for Appellee Helvetia Asset Recovery, Inc. (“Helvetia”). In support of
this motion, Haynes and Boone respectfully shows as follows:
1. Haynes and Boone wishes to withdraw as counsel of record for Helvetia.
Substituting as counsel of record will be:
1
Elizabeth Conry Davidson
Attorney at Law
Texas Bar No. 00793586
926 Chulie Drive
San Antonio, Texas 78216
Telephone: (210) 380-4899
Facsimile: (210) 225-2300
Email: conrydavidson@gmail.com
2. Contemporaneous with the filing of this motion, a copy of this motion will
be mailed to Helvetia Asset Recovery, Inc. both by certified mail and by first
class mail at its last known address.
WHEREFORE, Haynes and Boone, LLP, Werner A. Powers, and Lisa S.
Barkley respectfully request that the Court grant this Unopposed Motion for
Leave to Withdraw as Counsel of Record for Helvetia Asset Recovery, Inc., that
they be permitted to withdraw as counsel for Helvetia Asset Recovery, Inc., and
for such further relief to which they may be justly entitled.
2
HAYNES AND BOONE, LLP
/s/ Lisa S. Barkley
Werner A. Powers
State Bar No. 16218800
2323 Victory Avenue, Suite 700
Dallas, Texas 75219
Telephone: (214) 651-5000
Facsimile: (214) 651-5940
Werner.Powers@haynesboone.com
Lisa S. Barkley
State Bar No. 17851450
112 E. Pecan, Suite 1200
San Antonio, Texas 78205
Telephone: (210) 978-7427
Facsimile: (210) 554-0427
Lisa.Barkley@haynesboone.com
COUNSEL FOR APPELLEE
HELVETIA ASSET RECOVERY, INC.
CERTIFICATE OF CONFERENCE
I certify that I conferred with appellant Burton Kahn regarding this motion.
Mr. Kahn does not oppose the relief sought herein.
/s/ Lisa S. Barkley
Lisa S. Barkley
3
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this Unopposed Motion to
Withdraw as Counsel of Record has been provided to the following in accordance
with the Texas Rules of Appellate Procedure on this14th day of May, 2015:
Burton Kahn Via First Class and Certified Mail,
1706 Alpine Circle and electronic mail
San Antonio, Texas 78248
glentrail@yahoo.com
Helvetia Asset Recovery, Inc. Via First Class and Certified Mail,
c/o Robert Ripley, President and electronic mail
John Ripley, Vice-President
13123 Feather Point Drive
San Antonio, Texas 78233
rancherobob@gmail.com
jasper47@netzero.net
Elizabeth Conry Davidson Via First Class and Certified Mail,
Attorney at Law and electronic mail
Texas Bar No. 00793586
926 Chulie Drive
San Antonio, Texas 78216
Email: conrydavidson@gmail.com
/s/ Lisa S. Barkley
Lisa S. Barkley
4