ACCEPTED
12-14-00362-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
2/10/2015 12:18:08 PM
CATHY LUSK
CLERK
No. 12-14-00362-CV
In the Twelfth District Court of Appeals FILED IN
12th COURT OF APPEALS
Twelfth Court of Appeals District TYLER, TEXAS
For the State of Texas 2/10/2015 12:18:08 PM
CATHY S. LUSK
Clerk
Grace Smith,
Appellant
V.
Stephanie Holloway,
Appellee
Appeal from the County Court at Law Number 2
Gregg County, Texas,Hon. Judge Vincent Dulweber,Presiding
AGREED MOTION FOR SUBSTITUTION OF COUNSEL
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Appellee, STEPHANIE HOLLOWAY,(hereinafter "Appellee"), in the
above-numbered and styled cause, and files this Agreed Motion to Substitute Counsel and would
respectfully show unto the Court the following:
I.
Appellee requests that Gregory R. Ave and Matt Montgomery of the law firm of Walters,
Balido & Crain, L.L.P., Meadow Park Tower, 10440 North Central Expressway, Suite 1500,
Dallas, TX 75231, 214-749-4805, be substituted as her counsel of record in this case in place of
present counsel, Gregory W. Neeley of the Law Office of Gregory W. Neeley, 428 N. Fredonia
Street, Longview, TX 75601, 903-236-8900. Mr. Neeley has been appointed to serve as a Justice
on the 12TH Court of Appeals and thus is no longer able to handle the defense of this matter.
AGREED MOTION FOR SUBSTITUTION OF COUNSEL PAGE 1
H.
The requested substitution will result in no prejudice to any party involved in this
litigation.
WHEREFORE, PREMISES CONSIDERED, Appellee prays that the foregoing Agreed
Motion to Substitute Counsel by in all things is granted, and for such other and further relief to
which she may be justly entitled and will ever pray.
Respectfully submitted,
WALTERS,BALIDO & CRAIN,L.L.P.
/s/ Gregory R. Ave
GREGORY R. AVE
State Bar No. 01448900
MATT MONTGOMERY
State Bar No. 24041509
Meadow Park Tower
10440 North Central Expressway, Suite 1500
Dallas, TX 75231
Tel: 214-749-4805
Fax: 214-760-1670
NI-onto-omen/I/Fax f-(4Nvbc
COUNSEL FOR APPELLEE
STEPHANIE HOLLOWAY
APPROVED:
LAW OFFICE OF GREGORY W.NEELEY
Prior Counselfor Appellee
By: /s/ Gregory W. Neeley (with permission)
GREGORY W. NEELEY
State Bar No. 14861425
AGREED MOTION FOR SUBSTITUTION OF COUNSEL PAGE 2
CERTIFICATE OF SERVICE
On February 10, 2015, I served this Agreed Motion for Substitution of Counsel on all
counsel of record by email through the e-filing system.
/s/ Matt Montgomery
MATT MONTGOMERY
GREGORY R. AVE
CERTIFICATE OF CONFERENCE
This is to certify that counsel for Appellee has discussed this Motion with counsel for
Appellant and Appellant's counsel is unopposed to this Motion.
/s/ Matt Montgomery
MATT MONTGOMERY
GREGORY R. AVE
AGREED MOTION FOR SUBSTITUTION OF COUNSEL PAGE 3