3ECEIUB O8-lr:™O0€S3--CV <-•"> FEB 2 ?Q'5 COURT OF APPEALS DEMISE PAGHEHO, CLp;t EIGHTH DISTRICT OF TEXAS ALS EL PASO, TEXAS EIGHTH COURT 0- (•>; i

B.S., Appellant, § No. 08-15-00036-CV § v. § Appeal from the 394,h District Court of § TEXAS DEPARTMENT OF FAMILY § ,«—(XC # 7472>- AND PROTECTIVE SERVICES, \ ' ' Appellee \

MOTION FORWITHDRAWAL OF COUNSEL \ ^ This Motion for Withdrawal of Counsel is brought by Jeannette Duer, who is attorney of record for B.S. Jeannette Duer requests the Court to grant her permission to withdraw as attorney for B.S. in this case. In support, Jeannette Duer shows: Good cause exists for withdrawal of Jeannette Duer as counsel, in that she is unable to effectivelycommunicate with B.S. in a manner consistent with good attorney-client relations.

B.S. stated to the trial court that she wished to retain new counsel for the appellate process.

B.S. stated that she was not indigent and had funds to retain counsel for the appellate process.

A copy of this motion has been delivered to B.S., who is hereby notified in writing of her right to object to this motion. Brittany Segovia has not consented to the motion. The last known address of B.S. is 324 Walnut, Pecos, Texas.

Jeannette Duer prays that the Court enter an order discharging her as attorney of record for B.S.

Respectfully submitted, JEANNETTE DUER ATTORNEY AT LAW P.O. Box 2163 Fort Davis, Texas 79734 Tel: 432-426-3200 Cell: 713-557-0371 Fax: 432-426-3888

earjjiette Duer 7 "7 T ,r tate Bar No. 00793645 °^f p^h'W"^ [email protected] Law Office of Bart E. Medley P.O. Box 1937, Fort Davis, Texts 79734 (432)426-3222 voice (432)426-3227 fax barf@baftmed]ey.ccmi

VIA FACSIMILE ONLY February 2,2015 Hon. Denise Pacheco Clerk, 8* Court of Appeals E. San Antonio Ave. Room 1203 El Paso, Texas 79901 RE: Cause No. 08-15-00036-CV, BS, Appellant v. Texas Department ofFamilyand Protective Services, Appellee Dear Ms. Pacheco:

Attached please find a Motion to Withdraw as Counsel and a proposed order on that Motion in the above-referenced cause. This Motion is presented to the Court on behalfof Jeannette Duer, who is listed as the attorney for the appellant.

As I explained to someone in your office a few moments ago on the phone, Ms. Duer has recently assumed the office of Jeff Davis County Judge. Judge Duer is currently in Lubbock attending a training session for new county judges. As such, she has no ability to e-file this Motion and Order.

Judge Duer contacted me this afternoon, and stated that she had a deadline to file this Motion of 5:00 p.m. today. I am not involved in this case in any way, however, I offered to assist her in getting it filed. Unfortunately, since I represent no one in this matter, I cannot e-file it for her. Judge Duer has never been required to e-file before, and has advised me that she has no e- filing account I could use on her behalf.

Inmy conversation with your office, I was told that in exceptional circumstances, the Motion could be filed by fax andMs.Duer could be billed for the filing fee by mail or by e-mail.

I would submit thatthis is such an exceptional circumstance. Ms. Duer's mailing address, email address, and contact number are: Jeannette Duer P.O. Box 2163 Fort Davis, Texas 79734 (713)557-0371 cell [email protected] I would appreciate it ifyou would file this Motion onMs. Duer's behalf. Ifthere are any issues with this, please feel free to contact Ms. Duer at the number above.

Hon. Demise Pacheco February 2,2015 Page 2

Thank youforyourassistance inresolvingthisunusual issue. Shouldyouhaveanyquestions forme, I willbe happy to visitwithyou,although I knownothing whatsoever aboutthiscase. I can be reached at (915)526-6255 or by e-mail at [email protected].

Respectfully submitted,

BarfE. Medley State Bar No. 24035671 COURT OF APPEALS EIGHTH DISTRICT OF TEXA EL PASO, TEXAS B.S., Appellant, § No. 08-15-00036-CV § v. § Appeal from the 394* District Court of § TEXAS DEPARTMENT OF FAMILY § (TC#7472) AND PROTECTIVE SERVICES, Appellee ORDER REGARDING COUNSEL'S MOTION TO WITHDRAW

The Court entersthis ORDER discharging Jeannette Dueras attorney of record for B.S.