Mary Ann Castro v. Manuel Castro ( 2015 )

ACCEPTED
041400785CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
5/18/2015 4:04:32 PM
KEITH HOTTLE
CLERK
COURT OF APPEALS NO. 04-14-00785-CV
TRIAL COURT CASE NO. 2011 CI 15957 FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
IN THE MATTER OF § IN THE DISTRICT COURT
05/18/2015 4:04:32 PM
THE MARRIAGE OF §
KEITH E. HOTTLE
§ Clerk
MANUEL G. CASTRO § 45th JUDICIAL DISTRICT
AND §
MARY ANN CASTRO § BEXAR COUNTY, TEXAS
MOTION FOR WITHDRAWAL OF COUNSEL
This Motion for Withdrawal of Counsel is brought by JOSEPH P. APPELT, who is attorney of
record for MANUEL G. CASTRO in the trial court. Joseph P. Appelt, requests the Court to grant him
permission to withdraw as attorney for MANUEL G. CASTRO in this case. In support, Joseph P. Appelt
shows:
Good cause exists for withdrawal of Joseph P. Appelt, as counsel for Petitioner, MANUEL G.
CASTRO, due to a conflict arising between Attorney and Client which prevents effective representation.
A copy of this motion has been delivered to MANUEL G. CASTRO by CMRRR 7012 1010
0002 5767 6889 and regular mail; he is also hereby notified in writing of his right to object to this
motion. The last known address of MANUEL G. CASTRO is 23302 Hickory Shadow, Elmendorf,
Texas 78112
There are no settings or hearings pending in this matter.
A response to the Fourth Court of Appeals is due to their inquiry regarding Appellee’s past due
response brief. Said response to the Fourth Court is due May 18, 2015. Said response has been timely
filed.
Oral argument has been requested by Appellant but has not yet been granted or denied.
An entry of an order granting this motion and discharging Movant as attorney of record for
MANUEL G. CASTRO would not harm the other party.
NOTICE TO CLIENT
You have the right to object to this motion. If you do not oppose Joseph P. Appelt’s withdrawal
as your attorney, you may notify Joseph P. Appelt in writing of your consent to this motion.
Joseph P. Appelt prays that Court enter an order discharging him as attorney of record for
MANUEL G. CASTRO.
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Respectfully Submitted,
Joseph P. Appelt, P.C.
5825 Callaghan Rd., Ste. 104
San Antonio, Texas 78228
210/375-1212 (Telephone)
210/375-1213 (Telecopier)
By:
JOSEPH P. APPELT
SBN: 00789809
ATTORNEY FOR MANUEL G. CASTRO
CERTIFICATE OF SERVICE
I certify that a true copy of the above was served on each attorney of record or party in
accordance with the Texas Rules of Civil Procedure on May 18, 2015.
JOSEPH P. APPELT
Attorney for MANUEL G. CASTRO
Consented to this _____ day of May 2015:
______________________________
MANUEL G. CASTRO, Appellee
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NO. 2011 CI 15957
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
MANUEL G. CASTRO § 45th JUDICIAL DISTRICT
AND §
MARY ANN CASTRO § BEXAR COUNTY, TEXAS
ORDER
On this ______ day of ________________, 2015 came to be heard Movant’s Motion For
Withdrawal of Counsel. . The last known address of MANUEL G. CASTRO is 23302 Hickory Shadow,
Elmendorf, Texas 78112. The Court, finding good cause, hereby ORDERS said Motion GRANTED.
Signed _______________________.
____________________________
JUDGE PRESIDING
APPROVED AS TO FORM ONLY:
Joseph P. Appelt, P.C.
Attorney at Law
5825 Callaghan Rd., Ste. 104
San Antonio, Texas 78228
210/375-1212 (Telephone)
210/375-1213 (Telecopier)
By:
JOSEPH P. APPELT
Attorney for Petitioner
State Bar No. 00789809
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