UNOPPOSED MOTION TO PROCEED WITHOUT LOCAL COUNSEL 1

United States District Court

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

ARIANA GEORGE and RODNEY

BOONE, Individually and as 

Representative of the Estate of AMARI

BOONE, Deceased. 

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ACH CHILD AND FAMILY SERVICES,

SHELIA ROBERSON, CHAISITY

FRIDA-CARO, JALAH LAWRENCE, 

GOVERNOR GREG ABBOTT, IN HIS

CAPACITY OVER THE TEXAS

DEPARTMENT OF FAMILY AND 

PROTECTIVE SERVICES, AND 

COVENANT KIDS INC. D/B/A 

CK FAMILY SERVICES

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 CIVIL ACTION NO. 3:22-CV-1124-S

DEFENDANT, SHEILA ROBERSON’S UNOPPOSED MOTION FOR LEAVE TO 

PROCEED WITHOUT LOCAL COUNSEL

Pursuant to Local Rule 83.10(a), of the Local Rules of the Northern District of Texas, Movant, 

Newton, Jones & McNeely, H. Dwayne Newton (“Movant”), counsel for Defendant, Sheila Roberson, 

respectfully requests leave of Court to participate in this matter without local counsel. The undersigned 

has conferred with counsel for the other parties, who are not opposed to the relief sought herein. The 

undersigned, H. Dwayne Newton is admitted to practice in the Northern District of Texas. 

Movant’s offices are in Houston, Texas and Mr. Newton can readily appear at any hearing or 

setting in this Courter whether in Dallas or conducted via teleconferencing. Movant has read and is 

familiar with the Local Rules of the Northern District of Texas.

For the foregoing reasons, Movant respectfully requests that the Court grant this Motion and 

allow Movant to appear before this Court without local counsel.

Case 3:22-cv-01124-S Document 12 Filed 09/23/22 Page 1 of 3 PageID 473
UNOPPOSED MOTION TO PROCEED WITHOUT LOCAL COUNSEL 2

Respectfully submitted,

By:________________________________ 

H. Dwayne Newton

Attorney in Charge

State Bar No. 14977200

Federal ID No. 7298

Foster K. Baird

State Bar No. 24115144

3405 Marquart

Houston, Texas 77027

(713) 493-7620 - Telephone

(713) 493-7633 – Facsimile

dnewton@newton-lawyers.com 

fkbaird@newton-lawyers.com

OF COUNSEL

NEWTON, JONES & MCNEELY

ATTORNEYS FOR DEFENDANT 

SHEILA ROBERSON

CERTIFICATE OF CONFERENCE

The undersigned certifies that he has conferred with all counsel of record in 

connection with the above and forgoing Motion to Proceed without Local Counsel and 

there is no opposition to such Motion. 

By:________________________________ 

H. Dwayne Newton

Case 3:22-cv-01124-S Document 12 Filed 09/23/22 Page 2 of 3 PageID 474
UNOPPOSED MOTION TO PROCEED WITHOUT LOCAL COUNSEL 3

CERTIFICATE OF SERVICE

The undersigned certifies that on this the 22nd day of September 2022, the 

foregoing document was served via electronic service and if unavailable in accordance 

with the Federal Rules of Civil Procedure on the following counsel of record:

Attorneys for Plaintiffs Attorneys for Defendants, ACH Child and 

Family Services and Jalah Lawrence

Russell Button

Ashley Washington

The Button Law Firm

4315 W. Lovers Lane, Suite A

Dallas, Texas 75209

Heather Long

Heather Long Law P.C.

4310 N. Central Expressway

Dallas, Texas 75206

Jack M. Luckett

Mayer LLP

750 N. St. Paul Street, Suite 700

Dallas, Texas 75201

Attorneys for Chaisity Frida-Caro

Attorneys for Governor Greg Abbott, in his 

official capacity over the Texas Department of 

Family and Protective Services

J. Spencer Young

Quintairos, Prieto, Wood & Boyer, P.A.

1700 Pacific Avenue, Suite 4545

Dallas, Texas 75201

Leif Olson

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

By:________________________________ 

H. Dwayne Newton

Case 3:22-cv-01124-S Document 12 Filed 09/23/22 Page 3 of 3 PageID 475