# 3ECEIUB O8-lr:TMO0€S3--CV <-•">
FEB 2 ?Q'5 COURT OFAPPEALS 

## DEMISE PAGHEHO, CLp;t EIGHTH DISTRICTOF TEXAS EIGHTH COURT 0- (•>; i ALS EL PASO, TEXAS B.S., Appellant, § No. 08-15-00036-CV § 

### v. § Appealfrom 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 this motion 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 BarNo. 00793645 °^f p^h'W"^ jjduer@aol.com

### Law Office ofBart 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 of Familyand 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 of5:00 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 forher. 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, I was told thatinexceptional circumstances, the Motion could be filed by fax andMs. Duer could bebilled for thefiling feebymail or bye-mail. 

### I would submit thatthis is such 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


### Thankyouforyour assistance inresolvingthisunusual issue. Shouldyouhaveanyquestions forme, I willbe happy to visitwithyou,although Iknownothing whatsoeveraboutthis case. I can be reached at (915)526-6255 or by e-mail at bart@bartmedley.com. Respectfully submitted,

BarfE. Medley State Bar No. 24035671COURT OF APPEALS EIGHTH DISTRICT OF TEXA EL PASO, TEXAS 

### B.S., Appellant, § No. 08-15-00036-CV § 

### v. § Appealfrom the 394* District Court of § 

### TEXAS DEPARTMENT OFFAMILY § (TC#7472)

AND PROTECTIVE SERVICES, Appellee ORDER REGARDING COUNSEL'S MOTION TO WITHDRAW


### The Court entersthis ORDER discharging Jeannette Dueras attorney ofrecord for B.S.