Pamela Mehl v. David Stern

• Court: Court of Appeals of Texas
• Decided: January 30, 2015
• Docket: 03-14-00697-CV
• Status: Published

Opinion

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