{00095966}
N
O
.
15 0966
___________________________
I
N THE
T
EXAS
S
UPREME
C
OURT
S
TEVEN
G
REGORY
S
LOAT
,
E
D
B
RYAN
,
C
HURCH OF
S
CIENTOLOGY
I
NTERNATIONAL
,
D
AVID
J.
L
UBOW
A
ND
M
ONTY
D
RAKE
, P
ETITIONERS
V
. M
ONIQUE
R
ATHBUN
, R
ESPONDENT
On Petition for Review from the Texas Court of Appeals, Third District, at Austin Cause No. 03-14-00199-CV
U
NOPPOSED
M
OTION FOR
W
ITHDRAWAL OF
C
OUNSEL FOR
R
ESPONDENT AND FOR
L
IMITED
L
IFT OF
S
TAY
Counsel for
Monique Rathbun
file this Unopposed Motion for Withdrawal of Counsel for Respondent and for Limited Lift of Stay, and in support thereof would respectfully show the Court as follows:
FILED
15-0966
1/28/2016 5:24:23 PM
tex-8850998
SUPREME COURT OF TEXAS
BLAKE A. HAWTHORNE, CLERK
{00095966}
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2
̶
1.
Monique Rathbun has discharged the undersigned attorneys without cause. Accordingly, the undersigned attorneys seek to withdraw as counsel for Ms. Rathbun in these proceedings. 2.
Ms. Rathbun has been notified of the filing of this motion and, as reflected by her signature, does not oppose the relief requested herein. As set forth in the Certificate of Conference below, no other party objects to the request that the undersigned attorneys be allowed to withdraw. 3.
Notices to Ms. Rathbun can be mailed to 501 Sunset, Ingleside on the Bay, Texas 78362. 4.
This case is on interlocutory appeal pursuant to sections 27.003 and 51.014 of the Texas Civil Practice and Remedies Code. Pursuant to section 51.014(b), proceedings in the trial court are currently stayed, including proceedings against Defendants other than Petitioners herein. Accordingly, the undersigned counsel request that the Court lift the section 51.014(b) stay for the limited purpose of allowing Respondent’s counsel to withdraw from the currently-stayed proceedings. This request for a limited lifting of the stay is not sought for purposes of delay, but so that justice may be served.
{00095966}
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3
̶
W
HEREFORE
, Counsel for Monique Rathbun pray that this Motion be granted and that: 1.
The counsel listed below be permitted to withdraw as counsel for Respondent, Monique Rathbun; and 2.
The Court lift the stay imposed by section 51.014 of the Texas Civil Practice and Remedies Code for the limited purpose of allowing the counsel listed below to file and have heard a motion to withdraw as counsel in the trial court. Respectfully submitted,
P
ULMAN
,
C
APPUCCIO
, P
ULLEN
,
B
ENSON
&
J
ONES
,
LP
2161 NW Military Highway, Suite 400 San Antonio, Texas 78213 www.pulmanlaw.com (210) 222-9494 Telephone (210) 892-1610 Facsimile By:
/s/ Leslie Sara Hyman
Elliott S. Cappuccio Texas State Bar No. 24008419 ecappuccio@pulmanlaw.com Leslie Sara Hyman Texas State Bar No. 00798274 lhyman@pulmanlaw.com
J
EFFREY
L
AW
F
IRM
Ray B. Jeffrey Texas State Bar Number 10613700 2631 Bulverde Road, Suite 105 Bulverde, Texas 78163 (830) 438-8935 Telephone (830) 438-4958 Facsimile rjeffrey@sjmlawyers.com