Jonna G. Peltier and James Peltier v. Grant Garrison, Vogel Reanon, Nicole Hopson, Debbie Smith and Patrick Smith
Opinion
ACCEPTED
03-16-00855-CV
14452482
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/27/2016 12:08:10 PM
JEFFREY D. KYLE
CLERK
FILED IN
NO. 03-16-00855-CV 3rd COURT OF APPEALS AUSTIN, TEXAS
IN THE COURT OF APPEALS 12/27/2016 12:08:10 PM JEFFREY D. KYLE
Clerk
3RD JUDICIAL DISTRICT
AUSTIN, TEXAS
In re Mark Peltier and Jonna Peltier, Appellants
MOTION FOR WITHDRAWAL OF COUNSEL
JAMIE GRAHAM & ASSOCIATES, PLLC Jamie L. Graham State Bar No. 24027335 Audrey E. Manriquez State Bar No. 24029704 Tower Life Building 310 S. St. Mary's St., Suite 2500 San Antonio, Texas 78205 Tel: (210) 308-6448 Fax: (210) 308-5669 E-mail: jamie@jamiegrahamlaw.com Attorneys for Appellants
TO THE HONORABLE COURT OF APPEALS:
1. This Motion for Withdrawal of Counsel is brought by Jamie L. Graham
and Audrey E. Manriquez of JAMIE GRAHAM & ASSOCIATES, PLLC, who are
attorney of record for Jonna Peltier and James Mark Peltier. Jamie L. Graham and
Audrey E. Manriquez of JAMIE GRAHAM & ASSOCIATES, PLLC request the Court to
grant them permission to withdraw as attorney for Jonna Peltier and James Mark
Peltier in this case.
2. Good cause exists for withdrawal of Jamie L. Graham and Audrey E.
Manriquez of JAMIE GRAHAM & ASSOCIATES, PLLC as counsel, in that they are
unable to effectively communicate with Jonna Peltier and James Mark Peltier in a
manner consistent with good attorney-client relations.
3. A copy of this motion has been delivered to Jonna Peltier and James
Mark Peltier, who are hereby notified in writing of their right to object to this motion.
Jonna Peltier and James Mark Peltier have not consented to the motion.
4. The last known address of Jonna Peltier and James Mark Peltier is 1621
Mikula Place, New Braunfels, Texas, 78130, and the last known phone number of
Jonna Peltier and James Mark Peltier is (830) 822-4066.
5. The pending settings and deadlines in this case are as follows:
1) Fees Due in 3rd Court of Appeals- December 27, 2016
2) Docketing Statement Due in the 3rd Court of Appeals- December 27,
2016
3) Clerk’s Record Due in the 3rd Court of Appeals- February 7, 2017
4) Court reporter’s Record Due in the 3rd Court of Appeals- February 7,
2017
5) (Trial Court) Hearing on Motion for Enforcement in the Comal County
Courthouse Annex, 150 N. Seguin Street, New Braunfels, Texas on
December 30, 2016 at 9:00 a.m.
6. The following hearings have been held in this case and have been
recorded by the court reporters set forth below:
Type of Date of Transcript Transcript Court Reporter’s Hearing Hearing Requested? Received? Name, Address, Tel. No.
Motion to 07/10/2015 Yes Yes Dana Dance, 105 N. Modify Seguin, Suite 301, Temporary New Braunfels, Orders Texas 78130 Motion for 09/15/2016 No No Dana Dance, 105 N. Enforcement of Seguin, Suite 301, Possession or New Braunfels, Access Texas 78130 Order of 12/09/2016 Yes No Dana Dance, 105 N. Enforcement by Seguin, Suite 301, Contempt New Braunfels, Texas 78130
7. On entry of an order granting this motion and discharging Movants as
attorney of record for Jonna Peltier and James Mark Peltier, Movants will provide
Jonna Peltier and James Mark Peltier with the originals of all of Jonna Peltier and
James Mark Peltier’s discovery responses and documents Jonna Peltier and James
Mark Peltier have produced in response to discovery requests.
Notice to Client
You are hereby notified that this Motion for Withdrawal of Counsel has been
filed in the 3rd Court of Appeals. You do not have to agree to this motion. If you
wish to contest the withdrawal of Jamie L. Graham and Audrey E. Manriquez of
JAMIE GRAHAM & ASSOCIATES, PLLC as your attorney, you have a right to object.
If you do not oppose Jamie L. Graham and Audrey E. Manriquez of JAMIE GRAHAM
& ASSOCIATES, PLLC’S withdrawal as your attorney, you may notify Jamie L.
Graham and Audrey E. Manriquez of JAMIE GRAHAM & ASSOCIATES, PLLC in
writing of your consent to this motion.
Prayer
Jamie L. Graham and Audrey E. Manriquez of JAMIE GRAHAM & ASSOCIATES,
PLLC pray that the Court enter an order discharging them as attorney of record for
Jonna Peltier and James Mark Peltier.
Respectfully Submitted,
JAMIE GRAHAM & ASSOCIATES, PLLC Tower Life Building 310 S. St. Mary’s St., Suite 2500 San Antonio, Texas 78205 Tel. (210) 308-6448 Fax (210) 308-5669
By:/s/ Jamie L. Graham
Jamie L. Graham State Bar No. 24027335 Audrey E. Manriquez State Bar No. 24029704 Attorney for Respondents jamie@jamiegrahamlaw.com
Certificate of Service
I certify that a true copy of this Motion for Withdrawal of Counsel was served
in accordance with Rule 9.5 and Rule 6.5 of the Texas Rules of Appellate Procedure
on each party or that party's lead counsel as follows:
Via Facsimile @ 830-626-1414 The Bettersworth Law Firm 110 W. Faust Street New Braunfels, Texas 78130 Tel: 830-606-0404 Fax: 830-626-1414
Via First Class and Certified Mail Jonna Peltier and James Mark Peltier 1621 Mikula Place New Braunfels, Texas, 78130
/s/ Jamie L. Graham Jamie L. Graham Audrey E. Manriquez
Free access — add to your briefcase to read the full text and ask questions with AI
Jonna G. Peltier and James Peltier v. Grant Garrison, Vogel Reanon, Nicole Hopson, Debbie Smith and Patrick Smith (Jonna G. Peltier and James Peltier v. Grant Garrison, Vogel Reanon, Nicole Hopson, Debbie Smith and Patrick Smith) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.