999999\00195\1441486.1 C ASE N O

. 01-14-00844-CV

In the First Court of Appeals Houston, Texas

Neighborhood Centers, Inc., Appellant

v.

Doreatha Walker, Appellee and Cross-Appellant

From the 80th District Court, Harris County, Texas Cause No. 2014-37034

M OTION FOR L EAVE TO W ITHDRAW AND S UBSTITUTE N EW C OUNSEL , AND M OTION TO E XTEND T IME

Pursuant to Texas Rule of Appellat e Procedure 6.5, the below-signed

counsel file this motion for leave to withdraw and substitute new counsel for
Cross-Appellant/Appellee Doreatha Walk er, and to extend the September 21,
2015 deadline to respond to the motion for rehearing filed by Appellant
Neighborhood Centers, Inc. ACCEPTED 01-14-00844-CV FIRST COURT OF APPEALS

HOUSTON, TEXAS 9/14/2015 3:01:25 PM CHRISTOPHER PRINE

CLERK999999\00195\1441486.1 M OTION FOR L EAVE TO W ITHDRAW AND S UBSTITUTE N EW C OUNSEL The below-signed counsel respectfully request that the current lead

counsel be allowed to withdraw and no longer represent Ms. Walker in this

appeal. 1 Lorna McMillion and Lawrence M. Doss of M ULLIN H OARD B ROWN
LLP will represent Ms. Walker as ne w lead counsel in this appeal:

Lorna L. McMillion State Bar No. 24086726 Lawrence M. Doss State Bar No. 24012544 M ULLIN H OARD B ROWN LLP Wells Fargo Center, 1500 Broadway, Suite 700 Lubbock Texas 79401

806.765.7491 phone

806.765.0553 fax

PO Box 2585 Lubbock Texas 79408-2585 lmcmillion@mhba.com ldoss@mhba.com

A copy of this motion has been delivered to Ms. Walker at her last
known address by certified mail, first class mail, and email as indicated below:

Ms. Doreatha Walker 6806 Lost Thicket Drive Houston TX 77085
713.263.4699 tryjesustoo@yahoo.com

1 Former lead counsel joined a new law fi rm after briefing in this appeal was complete and less than two weeks before oral argument. Former lead counsel subsequently learned of an unexpected and indirect conflict of interest that would preclude further representation in this appeal when this Cour t issued its opinion and the existing agreement to provide pro bono services ended by its own te rms. As with the prio r motion to withdraw, Ms. Walker agrees with and consents to th is motion to withdraw and substitute new counsel.999999\00195\1441486.1 M OTION TO E XTEND T IME Additionally, Ms. Walker seeks a brief two-week extension of the

September 21, 2015 deadline to respond to the motion for rehearing filed by
Appellant Neighborhood Center, Inc., pursuant to Texas Rules of Appellate
Procedure 10.5(b).

Ms. Walker’s appeal to this Court was referred to the new lead counsel

through the pro bono program of the Texas State Bar and the Houston Bar

Association Appellate Section on Septembe r 9, 2015. Additional time is needed

to review the Court’s opinion and the reco rd on appeal, as well as to research
the issues raised in Neighborhood Ce nters, Inc.’s motion for rehearing.

Ms. Walker therefore requests that the Court vacate the September 21,

2015 deadline for Ms. Walker to file her response to the motion for rehearing,

and permit Ms. Walker to file respon se on Monday, October 5, 2015. This
motion is not brought for purpose of dela y, but rather so that justice may be

done.999999\00195\1441486.1 Respectfully submitted,

By: /s/ Whitney Rawlinson Whitney Rawlinson State Bar No. 24068655 4265 San Felipe, Suite 1200 Houston, Texas 77027 832.615.4228 phone 713.552.1758 fax wrawlinson@boyarmiller.com

FORMER COUNSEL FOR DOREATHA WALKER

and

By: /s/ Lorna L. McMillion Lorna L. McMillion State Bar No. 24086726 Lawrence M. Doss State Bar No. 24012544 M ULLIN H OARD B ROWN LLP Wells Fargo Center 1500 Broadway, Suite 700 Lubbock Texas 79401 806.765.7491 phone 806.765.0553 fax PO Box 2585 Lubbock Texas 79408-2585 lmcmillion@mhba.com ldoss@mhba.com

NEW COUNSEL FOR DOREATHA WALKER999999\00195\1441486.1 C ERTIFICATE OF C OMPLIANCE
I do hereby certify that I have conf erred with counsel for Appellant in this case, and counsel indicated that Appellant is unopposed to the relief sought in this motion.

/s/ Whitney Rawlinson Whitney Rawlinson

C ERTIFICATE OF C OMPLIANCE
I further hereby certify that this do cument complies with the typeface requirements of Texas Rule of Appellate Procedure 9.4(e) because it has been prepared in a proportionally spaced t ypeface using Microsoft Word 2013 in 14 point Bell MT font.

/s/ Whitney Rawlinson Whitney Rawlinson999999\00195\1441486.1 C ERTIFICATE OF S ERVICE
I further certify that on the 14 th day of September, 2015 a true and correct copy of the foregoing document wa s sent to all counsel of record as indicated below:

Linda P. Wills Wilson, Elser, Moskowitz, Edelman & Dicker, LLP 909 Fannin Street, Suite 3300 Houston, Texas 77010 713.353.2000 713.785.7780 fax linda.wills@wilsonelser.com by e-serve

Ms. Doreatha Walker Last known address: 6806 Lost Thicket Drive Houston TX 77085 tryjesustoo@yahoo.com by e-mail, first class mail, and certified mail, return receip t requested #7013 1710 0001 4236 9041

/s/ Whitney Rawlinson Whitney Rawlinson