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CASE NO. 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 

 

MOTION FOR LEAVE TO WITHDRAW AND SUBSTITUTE NEW COUNSEL,

AND MOTION TO EXTEND TIME

 

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

counsel file this motion for leave to withdraw and substitute new counsel for 

Cross-Appellant/Appellee Doreatha Walker, 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

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 9/14/2015 3:01:25 PM CHRISTOPHER A. PRINE Clerk
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MOTION FOR LEAVE TO WITHDRAW AND SUBSTITUTE NEW COUNSEL

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counsel be allowed to withdraw and no longer represent Ms.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 MULLIN HOARD BROWN

LLP will represent Ms. Walker as new lead counsel in this appeal: 

Lorna L. McMillion 

State Bar No. 24086726 

Lawrence M. Doss 

State Bar No. 24012544 

MULLIN HOARD BROWN 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 firm 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 Court issued its opinion and the existing agreement 

to provide pro bono services ended by its own terms. As with the prior motion to withdraw, 

Ms. Walker agrees with and consents to this motion to withdraw and substitute new 

counsel.
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MOTION TO EXTEND TIME

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 September 9, 2015. Additional time is needed 

to review the Court’s opinion and the record on appeal, as well as to research 

the issues raised in Neighborhood Centers, 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 response on Monday, October 5, 2015. This 

motion is not brought for purpose of delay, but rather so that justice may be 

done. 
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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 

MULLIN HOARD BROWN 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 

WALKER 
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CERTIFICATE OF COMPLIANCE

I do hereby certify that I have conferred 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 

CERTIFICATE OF COMPLIANCE

I further hereby certify that this document complies with the typeface 

requirements of Texas Rule of Appellate Procedure 9.4(e) because it has been 

prepared in a proportionally spaced typeface using Microsoft Word 2013 in 14 

point Bell MT font. 

/s/ Whitney Rawlinson 

Whitney Rawlinson 

 
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CERTIFICATE OF SERVICE

I further certify that on the 14th day of September, 2015 a true and 

correct copy of the foregoing document was 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 receipt requested #7013 1710 0001 4236 9041 

/s/ Whitney Rawlinson 

Whitney Rawlinson