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FEB 2 ?Q'5 COURT OF APPEALS

DEMISE PAGHEHO, CLp;t EIGHTH DISTRICT OF TEXAS

EIGHTH COURT 0- (•>; i ALS EL PASO, TEXAS

B.S., Appellant, § No. 08-15-00036-CV

§

v. § Appeal from the 394,h District Court of

§

TEXAS DEPARTMENT OF FAMILY § ,«—(XC # 7472>-

AND PROTECTIVE SERVICES, \ ' '

Appellee \

MOTION FORWITHDRAWAL OF COUNSEL \ ^

This Motion for Withdrawal ofCounsel is brought by Jeannette Duer, who is attorney of

record for B.S. Jeannette Duer requests the Court to grant her permission to withdraw as

attorney for B.S. in this case. In support, Jeannette Duer shows:

Good cause exists for withdrawal of Jeannette Duer as counsel, in that she is unable to

effectivelycommunicate with B.S. in a manner consistent with good attorney-clientrelations.

B.S. stated to the trial court that she wished to retain new counsel for the appellate

process.

B.S. stated that she was not indigent and had funds to retain counsel for the appellate

process.

A copy of thismotion hasbeen delivered to B.S., who is hereby notified in writing of her

right to object to this motion. Brittany Segovia has not consented to the motion. The last known

address ofB.S. is 324 Walnut, Pecos, Texas.

Jeannette Duer praysthat the Court enter an order discharging her as attorney of record

for B.S.
Respectfully submitted,

JEANNETTE DUER

ATTORNEY AT LAW

P.O. Box 2163

Fort Davis, Texas 79734

Tel: 432-426-3200

Cell: 713-557-0371

Fax: 432-426-3888

earjjiette Duer 7 "7 T ,r tate Bar No. 00793645 °^f p^h'W"^

jjduer@aol.com
Law Office of Bart E. Medley

P.O. Box 1937, Fort Davis, Texts 79734

(432)426-3222 voice (432)426-3227 fax barf@baftmed]ey.ccmi

VIA FACSIMILE ONLY

February 2,2015

Hon. Denise Pacheco

Clerk, 8* Court ofAppeals

500 E. San Antonio Ave.

Room 1203

El Paso, Texas 79901

RE: Cause No. 08-15-00036-CV, BS, Appellant v. Texas Department ofFamilyand

Protective Services, Appellee

Dear Ms. Pacheco:

Attachedplease find a Motion to Withdraw as Counsel and a proposed order on that

Motion in the above-referenced cause. This Motion is presented to the Court on behalfof

Jeannette Duer, who is listed as the attorney for the appellant.

As I explained to someone in your office a few moments ago on the phone, Ms. Duer has

recently assumed the office ofJeffDavis County Judge. Judge Duer is currentlyin Lubbock

attending a training session for new countyjudges. As such, she has no ability to e-file this

Motion and Order.

Judge Duer contacted me this afternoon, and stated that she had a deadline to file this

Motion of 5:00 p.m. today. I am not involved in this case in any way, however,I offered to assist

her in gettingit filed. Unfortunately, since I represent no one in this matter, I cannote-file it for

her. Judge Duer has never been required to e-file before, and has advised me that she has no efiling account I could use on her behalf.

Inmy conversation with your office, Iwas told thatinexceptional circumstances, the

Motion could be filed byfax andMs.Duer could be billed for the filing feebymail or bye-mail.

I would submit thatthis issuch an exceptional circumstance. Ms. Duer's mailing address, email

address, and contact number are:

Jeannette Duer

P.O. Box 2163

Fort Davis, Texas 79734

(713)557-0371 cell

jjduer@aol.com

Iwould appreciate it ifyou would file this Motion onMs. Duer's behalf. Ifthere are any

issues with this, please feel free to contact Ms. Duer at the number above.
Hon. Demise Pacheco

February 2,2015

Page 2

Thank youforyourassistance inresolvingthisunusual issue. Shouldyouhaveanyquestions

forme, I willbe happy to visitwithyou,although Iknownothing whatsoever aboutthiscase. I can

be reached at (915)526-6255 or by e-mail at bart@bartmedley.com.

Respectfully submitted,

BarfE. Medley

State Bar No. 24035671
COURT OF APPEALS

EIGHTH DISTRICT OF TEXA

EL PASO, TEXAS

B.S., Appellant, § No. 08-15-00036-CV

§

v. § Appeal from the 394* District Court of

§

TEXAS DEPARTMENT OFFAMILY § (TC#7472)

AND PROTECTIVE SERVICES,

Appellee

ORDER REGARDING COUNSEL'S MOTION TO WITHDRAW

TheCourt entersthisORDER discharging Jeannette Dueras attorney of record for B.S.