Troy Thoele, Mike Barro, Ryan Partlow, Adam Ouda, and Troy Richard v. Rene Hinojosa, in His Official Capacity as the Director of the Parole Division of the Texas Department of Criminal Justice; David Gutierrez in His Official Capacity as Chairman of the Texas Board of Pardons and Paroles; And the Texas Board of Pardons and Paroles

ACCEPTED 15-24-00008-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/3/2025 3:48 PM CHRISTOPHER A. PRINE Case Number 15-24-0008-CV CLERK FILED IN In the Fifteenth Court of Appeals 15th COURT OF APPEALS Troy Thoele, Mike Barro, Ryan Partlow AUSTIN, TEXAS Adam Ouda, and all others similarly situated, 2/3/2025 3:48:01 PM CHRISTOPHER A. PRINE Clerk Appellants/Petitioners v. Rene Hinojosa, in his official capacity as the Director of the Parole Division of the Texas Department of Criminal Justice; David Gutierrez, in his official capacity as Chairman of the Texas Board of Pardons and Paroles, and The Texas Board of Pardons and Paroles; Appellees/Respondents On Appeal from the 353RD District Court of Travis County, Texas Trial Court Case No. D-1-GN-22-006192 MOTION TO WITHDRAW AS LEAD COUNSEL FOR APPELLANTS/PETITIONERS AND SUBSTITUTE LEAD COUNSEL

PLEASE TAKE NOTICE that the undersigned attorney, Norma Esquivel, respectfully moves this Court for leave to withdraw as lead counsel for the Appellants/Petitioners in the above- captioned matter because the undersigned has resigned from LatinoJustice PRLDEF and her last day of employment with the organization will be February 4, 2025. Pursuant to Rule 6.5(d) of the Texas Rule of Appellate Procedure, the undersigned moves this Court to substitute her with Andrew Case Esq. as lead counsel. Mr. Case is already an attorney of record for the Appellants/Petitioners in the above-captioned matter. Mr. Case’s mailing address and telephone number are as follows: 475 Riverside Drive, Suite 1901, New York, NY, 10115, 212-219-3360.

The undersigned has already advised Appellants/Petitioners of her intention to withdraw as lead counsel in this matter and pursuant to Rule 6.5(b) of the Texas Rules of Appellate Procedure, has sent them a copy of this motion via first-class, certified mail at their last known addresses. The undersigned has also notified Appellants/Petitioners that Mr. Case will be lead counsel if this motion is granted. Other attorneys from LatinoJustice PRLDEF and Webber Law will remain co-counsel for the Appellants/Petitioners, and no party will be prejudiced if this motion is granted.

WHEREFORE, undersigned counsel and Appellants/Petitioners respectfully request that this Court permit Norma Esquivel to withdraw as lead counsel of record and substitute her with Andrew Case as lead counsel.

Dated: February 3, 2025 New York, New York By: /s/ Norma Esquivel Norma Esquivel, pro hac vice Riverside Drive, Ste. 1901 New York, NY 10115 (212) 219-3360 [email protected] CERTIFICATE OF SERVICE I hereby certify that on February 3, 2025, I caused to be served a true and correct copy of the above and foregoing document on the attorneys of record via electronic service and/or electronic mail.

/s/ Karen Muñoz Treviño Karen Muñoz Treviño Associate Counsel LatinoJustice PRLDEF Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Karen Munoz Trevino on behalf of Karen Munoz Trevino Bar No. 24120301 [email protected] Envelope ID: 96923792 Filing Code Description: Motion Filing Description: Motion to Withdraw as Lead Counsel and Substitute Lead Counsel Status as of 2/3/2025 4:04 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca Webber 24060805 [email protected] 2/3/2025 3:48:01 PM SENT Rosalind Hunt [email protected] 2/3/2025 3:48:01 PM SENT Jeff Lutz [email protected] 2/3/2025 3:48:01 PM SENT Ted Ross [email protected] 2/3/2025 3:48:01 PM SENT Jennifer Foster [email protected] 2/3/2025 3:48:01 PM SENT Lauren McGee [email protected] 2/3/2025 3:48:01 PM SENT Norma Esquivel [email protected] 2/3/2025 3:48:01 PM SENT Andrew Case [email protected] 2/3/2025 3:48:01 PM SENT Karen Munoz [email protected] 2/3/2025 3:48:01 PM SENT