in Re: A Purported Lien or Claim Against Helvetia Asset Recovery, Inc. ( 2015 )

ACCEPTED 04-14-00357-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 5/14/2015 1:59:05 PM KEITH HOTTLE CLERK NO. 04-14-00357-CV __________________________________________________________________ FILED IN 4th COURT OF APPEALS IN THE COURT OF APPEALS SAN ANTONIO, TEXAS FOR THE FOURTH DISTRICT OF TEXAS 05/14/2015 1:59:05 PM __________________________________________________________________ KEITH E. HOTTLE Clerk 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 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 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 4