NO. 04-14-00357-CV

__________________________________________________________________

IN THE COURT OF APPEALS

FOR THE FOURTH DISTRICT OF TEXAS

__________________________________________________________________

IN RE:

A PURPORTED LIEN OR CLAIM 

AGAINST HELVETIA ASSET RECOVERY, INC.

__________________________________________________________________

ON APPEAL FROM THE 224TH JUDICIAL DISTRICT COURT

BEXAR COUNTY, TEXAS

CAUSE NO. 2013-CI-18394

__________________________________________________________________

HAYNES AND BOONE, LLP’S UNOPPOSED MOTION FOR 

LEAVE TO WITHDRAW AS COUNSEL OF RECORD FOR APPELLEE 

HELVETIA ASSET RECOVERY, INC.

TO THE HONORABLE COURT OF APPEALS:

In accordance with Rule 6.5 of the Texas Rules of Appellate Procedure, 

Haynes and Boone, Werner A. Powers, and Lisa S. Barkley (collectively “Haynes 

and Boone”) file this Unopposed Motion for Leave to Withdraw as Counsel of 

Record for Appellee Helvetia Asset Recovery, Inc. (“Helvetia”). In support of 

this motion, Haynes and Boone respectfully shows as follows:

1. Haynes and Boone wishes to withdraw as counsel of record for Helvetia. 

Substituting as counsel of record is:

1 

ACCEPTED

04-14-00357-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

5/14/2015 1:59:05 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 05/14/2015 1:59:05 PM KEITH E. HOTTLE Clerk
Elizabeth Conry Davidson

Attorney at Law

Texas Bar No. 00793586

926 Chulie Drive

San Antonio, Texas 78216

Telephone: (210) 380-4899

Facsimile: (210) 225-2300

Email: conrydavidson@gmail.com

2. Contemporaneous with the filing of this motion, a copy of this motion will 

be mailed to Helvetia both by certified mail and by first class mail at its last 

known address. 

WHEREFORE, Haynes and Boone, LLP, Werner A. Powers, and Lisa S. 

Barkley respectfully request that the Court grant this Unopposed Motion for 

Leave to Withdraw as Counsel of Record for Helvetia Asset Recovery, Inc., that 

they be permitted to withdraw as counsel of record for Helvetia Asset Recovery, 

Inc., and for such other relief to which they may be justly entitled.

2
HAYNES AND BOONE, LLP

/s/ Lisa S. Barkley

Werner A. Powers

State Bar No. 16218800

2323 Victory Avenue, Suite 700

Dallas, Texas 75219

Telephone: (214) 651-5000

Facsimile: (214) 651-5940

Werner.Powers@haynesboone.com

Lisa S. Barkley

State Bar No. 17851450

112 E. Pecan, Suite 1200

San Antonio, Texas 78205

Telephone: (210) 978-7427

Facsimile: (210) 554-0427

Lisa.Barkley@haynesboone.com

COUNSEL FOR APPELLEE

HELVETIA ASSET RECOVERY,INC.

CERTIFICATE OF CONFERENCE

I certify that I conferred with appellant Burton Kahn regarding this motion. 

Mr. Kahn does not oppose the relief sought herein.

/s/ Lisa S. Barkley

Lisa S. Barkley

3
4 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of this Unopposed Motion to 

Withdraw as Counsel of Record has been provided to the following in accordance 

with the Texas Rules of Appellate Procedure on this14th day of May, 2015: 

Burton Kahn Via First Class and Certified Mail,

1706 Alpine Circle and electronic mail

San Antonio, Texas 78248 

glentrail@yahoo.com 

Helvetia Asset Recovery, Inc. Via First Class and Certified Mail,

c/o Robert Ripley, President and electronic mail

 John Ripley, Vice-President 

13123 Feather Point Drive 

San Antonio, Texas 78233 

rancherobob@gmail.com 

jasper47@netzero.net 

Elizabeth Conry Davidson Via First Class and Certified Mail, 

Attorney at Law and electronic mail

Texas Bar No. 00793586 

926 Chulie Drive 

San Antonio, Texas 78216 

Email: conrydavidson@gmail.com 

 /s/ Lisa S. Barkley 

Lisa S. Barkley