Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 2/27/2015 2:35:07 PM JEFFREY D. KYLE Clerk No. 03-13-00060-CV THIRD COURT OF APPEALS 2/27/2015 2:35:07 PM JEFFREY D. KYLE 03-13-00060-CV AUSTIN, TEXAS *1 ACCEPTED CLERK
In the
Third Court of Appeals
Austin, Texas Homer Alvarado and Valania Alvarado,
Appellants,
v.
The Abijah Group, Inc. d/b/a and f/k/a Baker
Surveying and Engineering, Inc.,
Appellee. From the 424 Judicial District Court
Blanco County, Texas
Honorable Don Leonard (Retired), Judge Presiding A PPELLEE ’ S U NOPPOSED M OTION FOR S UBSTITUTION
OF C OUNSEL T O THE H ONORABLE C OURT OF A PPEALS :
NOW COMES, The Abijah Group, Inc. d/b/a and f/k/a Baker Surveying and
Engineering, Inc., Appellee in the above cause and files this Unopposed Motion for
Substitution of Counsel and would show the Court the following: This Motion is to advise the Court that J. Ken Nunley, one of the attorneys for
Appellee, passed away on September 30, 2013, and Appellee’s other attorney of record is no
longer an employee of The Nunley Firm. Chad M. Upham respectfully requests this Court grant this Unopposed Motion for
Substitution of Counsel and allow him to appear as the attorney of record for Appellee.
Appellee agrees to this substitution of counsel and Appellants have no opposition to this
motion.
WHEREFORE, Appellee The Abijah Group, Inc. d/b/a and f/k/a Baker Surveying and
Engineering, Inc. prays that this motion be granted and that the court substitute Chad M.
Upham as the attorney of record for Appellee.
Respectfully submitted,
THE NUNLEY FIRM
1580 South Main Street; Suite 200
Boerne, Texas 78006
830/816-3333
830/816-3388 (fax)
BY: /s/ Chad M. Upham
CHAD M. UPHAM SBN: 24028178 Attorneys for Appellee, The Abijah Group, Inc. d/b/a and
f/k/a Baker Surveying and Engineering, Inc.
Certificate of Conference
On February 27, 2015, Chad M. Upham conferred by email with Michael S.
Truesdale, counsel for Appellants, regarding this motion. Mr. Truesdale responded that
Appellants do not oppose the motion.
/s/ Chad M. Upham CHAD M. UPHAM *3 Certificate of Service
I hereby certify that a true and correct copy of the above and foregoing has been
served via email on the 27 day of February, 2015 to the following:
Mr. Michael S. Truesdale
Law Office of Michael S. Truesdale, PLLC
801 West Avenue, Suite 201
Austin, Texas 78701
/s/ Chad M. Upham Chad M. Upham