Case Information
*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 05/14/2015 1:59:05 PM KEITH E. HOTTLE Clerk *1 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 __________________________________________________________________
I N THE C OURT OF A PPEALS F OR THE F OURTH D ISTRICT OF T EXAS
__________________________________________________________________
IN RE: A PURPORTED LIEN OR CLAIM
AGAINST HELVETIA ASSET RECOVERY, INC.
__________________________________________________________________
O N A PPEAL FROM THE 224 TH J UDICIAL D ISTRICT C OURT
B EXAR C OUNTY , T EXAS C AUSE N O . 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:
Elizabeth Conry Davidson
Attorney at Law
Texas Bar No. 00793586
926 Chulie Drive
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.
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 Telephone: (210) 978-7427 Facsimile: (210) 554-0427 Lisa.Barkley@haynesboone.com C OUNSEL FOR A PPELLEE H ELVETIA A SSET R ECOVERY , I NC . 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 *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: Via First Class and Certified Mail,
Burton Kahn and electronic mail
1706 Alpine Circle
San Antonio, Texas 78248
glentrail@yahoo.com Via First Class and Certified Mail,
Helvetia Asset Recovery, Inc.
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 Via First Class and Certified Mail,
Elizabeth Conry Davidson
Attorney at Law and electronic mail
Texas Bar No. 00793586
926 Chulie Drive
Email: conrydavidson@gmail.com
/s/ Lisa S. Barkley Lisa S. Barkley