NOTICE: THIS DOCUMENT CONTAINS SENTIVE DATA

CAUSE NO .2023-19031

IN THE MATTER OF THE § IN THE DISTRICT COURT

MARRIAGE OF §
§
§
BEATRIZ CHRISTINA HERRICK § 310 JUDICIAL DISTRICT
AND §
JOHN DAVID HERRICK § HARRIS COUNT, TEXAS

MOTION IN OBJECTION TO MOTION FOR WITHDRAWAL OF COUNSEL

I am writing to object to the motion to withdraw of counsel filed by the Law Office of Bryan
Fagan, PLLC, and Madeline Herrera in the above referenced case. I believe that the withdrawal
would be detrimental to my case and that the Law Office of Bryan Fagan, LLC, and Madeline
Herrera should not be allowed to withdraw.

While I acknowledge that there is an outstanding balance on my account, I believe that the Law
Office of Bryan Fagan, PLLC, has received more than reasonable fees for the services provided. I
have paid over $7,743.00 for an Original Petition for Divorce, an improper/premature Motion
for Default Decree, and Initial Disclosures. I have repeatedly requested a Motion for Temporary
Orders for Spousal Maintenance and Interim Attorney fees and the Motion still has not been
filed. On June 8, 2023, my Initial Disclosures were timely filed. My husband received the
disclosures and decided not to participate. Ms. Herrera told me that she would be filing a
motion to compel and a motion for sanctions the next day, but all work stopped on June 8,
2023.

I have paid my attorney a substantial amount of money for legal services, but I have not received
the level of representation expected. Linda Tappa was the original attorney assigned to
represent me. Ms. Tappa repeatedly failed to handle my matter in a diligent and competent
manner. She failed to communicate with me regarding the scope of work and her strategy to
obtain my objectives, she missed important deadlines which caused unnecessary and
unreasonable bills to be debited from my bank account. She did not provide me with the level of
representation that I need. The Law Office of Bryan Fagan, PLLC, offered to reassign another
attorney to represent me. Madeline Herrera substituted in on June 5, 2023. I believe that
Madeline Herrera is competent and able to handle my matter.

I believe that the Law Office of Bryan Fagan, PLLC, and Madeline Herrera’s motion to withdraw
is unjustified and premature. I am willing to work with the Law Office of Bryan Fagan to resolve
any fee disputes.

I respectfully request that the court deny my attorney’s motion to withdraw and require her to
continue representing me in this matter. I also believe that the Law Office of Bryan Fagan, PLLC
has received more than reasonable fees for the amount and quality of services provided.