IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

JONATHAN VILLAREAL, individually 

and derivatively on behalf of 

ZROBLACK, LLC. 

Plaintiffs, 

v. 

JOHN SAENZ, MIGUEL 

VILLARREAL, JR., and GUNN, LEE, 

& CAVE, P.C.

Defendants

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CIVIL ACTION NO. 5:20-CV-00571-OLG

CHARLES M.R. VETHAN’S, JOSEPH L. LANZA’S, AND THE VETHAN LAW FIRM’S

MOTION TO WITHDRAW AS ATTORNEY IN CHARGE

________________________________________________________________________

Charles M.R. Vethan, Joseph L. Lanza, and the Vethan Law Firm, P.C. asks this Court to

allow them to withdraw as attorney in charge for Plaintiff JONATHAN VILLAREAL and 

ZROBLACK, LLC. 

I. INTRODUCTION

Charles M.R. Vethan, Joseph L. Lanza, and the Vethan Law Firm, P.C. represent 

Plaintiff Jonathan Villareal. 

Plaintiffs sued Defendant John Saenz for (1) violations of the DTSA and TUTSA; 

(2) violations of the CFAA; (3) violations of the ACPA; (4) breach of contract; (5) breach of 

fiduciary duty; (6) tortious interference with prospective business relations; (7) conversion; (8) 

violation of the Texas Theft Liability Act; and (9) fraud and sought a declaration pursuant to 28 

U.S.C. § 2201 that the ZroBlack Operating Agreement and Release are void and unenforceable 

due to fraud and mutual mistake. 

Case 5:20-cv-00571-OLG Document 60 Filed 05/19/21 Page 1 of 5
Plaintiffs sued Defendants Villarreal, Jr. and Gunn, Lee, & Cave, P.C., for state law 

legal malpractice and breach-of-fiduciary duty claims. 

II. ARGUMENT

There is a good cause for this Court to grant the motion to withdraw. Plaintiffs have 

terminated the services of the firm and its attorneys, including Charles M.R. Vethan and Joseph L. 

Lanza. Plaintiffs have directed counsel to file this motion to withdraw immediately.

Plaintiffs’ last known address is 179 Enterprise Parkway #101, Boerne, Texas 

78006. Plaintiffs have been sent a copy of this motion.

Plaintiff currently has the following deadlines pending:

a. Deadline to file objections to Magistrate’s Report and Recommendations on 

Plaintiffs’ Application for Seizure an Injunctive Relief (Doc. 58): Friday, May 28, 

2021.

b. Deadline to file objections to Magistrate’s Report and Recommendations on 

Defendants’ Rule 12(b)(6) Motions to Dismiss (Doc. 59): Tuesday, June 1,2021.

Plaintiffs have been advised of these deadlines in writing.

III. CERTIFICATE OF CONFERENCE

The undersigned has conferred with counsel representing the Defendants regarding 

the subject matter of this motion. Counsel for Defendants have advised that they are not opposed 

to this motion.

IV. CONCLUSION

For the reasons of termination of the firm’s services at the request of the client, 

Charles M.R. Vethan, Joseph L. Lanza, and the Vethan Law Firm, P.C. ask this Court to grant 

Case 5:20-cv-00571-OLG Document 60 Filed 05/19/21 Page 2 of 5
their motion to withdraw from further representation of Plaintiffs Jonathan Villareal and ZroBlack, 

LLC and relieve counsel of any further responsibility for this matter.

Respectfully submitted,

THE VETHAN LAW FIRM, PC

By: /s/ Joseph L. Lanza

Charles M. R. Vethan 

Attorney-in-Charge

Texas Bar No. 00791852

VETHAN LAW FIRM - HOUSTON

Two Memorial City Plaza

820 Gessner, Suite 1510

Houston, Texas 77024

Tel: (713) 526-2222

Fax: (713) 526-2230

Email: edocs@vwtexlaw.com

Joseph L. Lanza

Texas bar No. 00784447

VETHAN LAW FIRM – SAN ANTONIO

11459 Huebner, Suite 101

San Antonio, Texas 78230

Tel: (210) 824-2220

Fax: (713) 526-2230

Email: edocs@vwtexlaw.com

Attorneys for Plaintiffs

CERTIFICATE OF CONFERENCE

Case 5:20-cv-00571-OLG Document 60 Filed 05/19/21 Page 3 of 5
I, undersigned attorney, hereby certify to the Court that I have conferred with opposing 

counsel in an effort to resolve the issues contained in this motion without the necessity of Court 

intervention, and opposing counsels ARE NOT OPPOSED to this Motion to Withdraw as Counsel. 

Certified on the 19

th of May 2021.

/s/ Joseph L. Lanza

 Joseph L. Lanza

Case 5:20-cv-00571-OLG Document 60 Filed 05/19/21 Page 4 of 5
CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was electronically filed with the Court on the

19th day of May 2021, and electronically served on the date reflected in the ECF system upon all

parties registered to receive notice pursuant to the Court’s CM/ECF system.

David A. Vanderhinder

State bar No. 24070787

DVanderhinder@dykema.com

Ryan J. Sullivan

State Bar No. 24102548

RSullivan@dykema.com

DYKEMA GOSSETT PLLC

112 East Pecan St., Suite 1800

San Antonio, Texas 78205

Attorney for Defendant John Saenz

George R. Spencer, Jr.

State Bar. No. 18921001

gspencer@langleybanack.com

Natalie F. Wilson

State Bar. No. 24067769

nwilson@langleybanack.com

Attorneys for Defendants Gunn, Lee & Cave, P.C.

And Miguel Villarreal, Jr.

/s/ Joseph L. Lanza

 Joseph L. Lanza

Case 5:20-cv-00571-OLG Document 60 Filed 05/19/21 Page 5 of 5