On September 04, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
and
for MODIFICATION-CUSTODY
in the District Court of Tarrant County.
Preview
• •
360-543013-13 FILED
TARRANT COUNTY
6/18/2014 10:06:16 AM
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA. THOMAS A. WILDER
DISTRICT CLERK
NO. 360-543013-13
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
ROBIN NICOLE WADE §
AND § 360TH JUDICIAL DISTRICT
DANIEL ALLEN WADE §
§
AND IN THE INTEREST OF §
B.M.W., G.D.W. AND R.C.W., § TARRANT COUNTY, TEXAS
CHILDREN §
PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL
This Motion for Withdrawal of Counsel is brought by Brent Schellhammer of Legal Aid of
Northwest Texas, who is attorney of record for ROBIN NICOLE WADE. Brent Schellhammer
of Legal Aid ofNortbwest Texas requests the Court to grant him permission to withdraw as
attorney for ROBIN NICOLE WADE in this case. In support, Brent Schellhammer of Legal Aid
ofNortbwest Texas shows:
Good cause exists for withdrawal of Brent Schellhammer of Legal Aid ofN ortbwest Texas
as counsel, in that he is unable to effectively communicate with ROBIN NICOLE WADE in a
manner consistent with good attorney-client relations.
A copy of this motion has been delivered to ROBIN NICOLE WADE, who is hereby
notified in writing of her right to object to this motion. ROBIN NICOLE WADE has not
consented to the motion. The last known address of ROBIN NICOLE WADE is 10756 Many
Oaks Drive, Fort Worth, Texas, 76104.
The settings and deadlines, including discovery deadlines, in this case are as follows:
Final Trial is set for September 4, 2014 at 1:30 p.m. for one to two hours.
The following hearings have been held in this case and have been recorded by the court
reporters set forth below: COURT'S ~NUTE~ 1
TRANSACTION ft (') I
PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL
In the Matter of the Marriage of Robin Wade and Daniel Wade ~din the Interest of the Wade Page I
'
360-543013-13
Type of Date of Transcript Transcript Court Reporter's
Hearing Hearing Requested? Received? Name, Address,
Tel. No.
!Temporary Orders I 9-16-13 No N/A
The discovery period in this suit will continue until the deadline prescribed by the Texas
Rules of Civil Procedure.
No discovery requests have been served by either party in this case.
There have not been any oral depositions in this case.
On entry of an order granting this motion and discharging Movant as attorney of record for
ROBIN NICOLE WADE, Movant will provide ROBIN NICOLE WADE with the originals of all
of ROBIN NICOLE WADE's discovery responses and documents ROBIN NICOLE WADE has
produced in response to discovery requests.
Notice to Client
You are hereby notified that this Motion for Withdrawal of Counsel is set for hearing at the
time and place stated below. You do not have to agree to this motion. If you wish to contest the
withdrawal of Brent Schellhanuner of Legal Aid ofNorthwest Texas as your attorney, you should
appear at the hearing. If you do not oppose Brent Schellhammer of Legal Aid of Northwest
Texas's withdrawal as your attorney, you may notifY Brent Schellhanuner of Legal Aid of
Northwest Texas in writing of your consent to this motion.
Brent Schellhanuner of Legal Aid of Northwest Texas prays that the Court enter an order
discharging him as attorney of record for ROBIN NICOLE WADE.
Respectfully submitted,
Legal Aid Of NorthWest Texas
600 E. Weatherford St.
Fort Worth, Texas 76102
Tel: (817) 339-5305
Fax: (817) 877-0804
PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL
In the Maner ofthe Marriage of Robin Wade and Daniel Wade and in the Interest of the Wade Page2
' .
'""~:'~~ I'lrentSCheiihammer
Of Legal Aid of Northwest Texas
State Bar No. 24029827
E-Mail: Schellhammerb@lanwt.org
Attorney for ROBIN NICOLE WADE
Notice of Hearing IJ-ei..lu.AJ }- ·tfau
The above motion is set for hearing on ~{ ti!;~ at~B'b hin.
in the 360th District Court of Tarrant County, Texas.
SIGNED on :AO dZQI
'
Certificate of Conference and Certificate of Service
A conference was not held with the Respondent, DANIEL ALLEN WADE, on the merits
of this motion because he is pro se and a hearing is necessary for the Court to give consent to the
relief requested in the motion.
I certify that a true copy of the above was served on each attorney of record or party in
~=-o wiili""' T= Rill~ ofCi"il l'ro«d~ _/
Brent Schellhammer
of Legal Aid of Northwest Texas
Attorney for ROBIN NICOLE WADE
PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL
In the Matter of the Marriage ofRobin Wade and Daniel Wade md in the Interest of the Wade Page3
Document Filed Date
June 20, 2014
Case Filing Date
September 04, 2013
Category
MODIFICATION-CUSTODY
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• • 360-543013-13 FILED TARRANT COUNTY 6/18/2014 10:06:16 AM NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA. THOMAS A. WILDER DISTRICT CLERK NO. 360-543013-13 IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § ROBIN NICOLE WADE § AND § 360TH JUDICIAL DISTRICT DANIEL ALLEN WADE § § AND IN THE INTEREST OF § B.M.W., G.D.W. AND R.C.W., § TARRANT COUNTY, TEXAS CHILDREN § PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL This Motion for Withdrawal of Counsel is brought by Brent Schellhammer of Legal Aid of Northwest Texas, who is attorney of record for ROBIN NICOLE WADE. Brent Schellhammer of Legal Aid ofNortbwest Texas requests the Court to grant him permission to withdraw as attorney for ROBIN NICOLE WADE in this case. In support, Brent Schellhammer of Legal Aid ofNortbwest Texas shows: Good cause exists for withdrawal of Brent Schellhammer of Legal Aid ofN ortbwest Texas as counsel, in that he is unable to effectively communicate with ROBIN NICOLE WADE in a manner consistent with good attorney-client relations. A copy of this motion has been delivered to ROBIN NICOLE WADE, who is hereby notified in writing of her right to object to this motion. ROBIN NICOLE WADE has not consented to the motion. The last known address of ROBIN NICOLE WADE is 10756 Many Oaks Drive, Fort Worth, Texas, 76104. The settings and deadlines, including discovery deadlines, in this case are as follows: Final Trial is set for September 4, 2014 at 1:30 p.m. for one to two hours. The following hearings have been held in this case and have been recorded by the court reporters set forth below: COURT'S ~NUTE~ 1 TRANSACTION ft (') I PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL In the Matter of the Marriage of Robin Wade and Daniel Wade ~din the Interest of the Wade Page I ' 360-543013-13 Type of Date of Transcript Transcript Court Reporter's Hearing Hearing Requested? Received? Name, Address, Tel. No. !Temporary Orders I 9-16-13 No N/A The discovery period in this suit will continue until the deadline prescribed by the Texas Rules of Civil Procedure. No discovery requests have been served by either party in this case. There have not been any oral depositions in this case. On entry of an order granting this motion and discharging Movant as attorney of record for ROBIN NICOLE WADE, Movant will provide ROBIN NICOLE WADE with the originals of all of ROBIN NICOLE WADE's discovery responses and documents ROBIN NICOLE WADE has produced in response to discovery requests. Notice to Client You are hereby notified that this Motion for Withdrawal of Counsel is set for hearing at the time and place stated below. You do not have to agree to this motion. If you wish to contest the withdrawal of Brent Schellhanuner of Legal Aid ofNorthwest Texas as your attorney, you should appear at the hearing. If you do not oppose Brent Schellhammer of Legal Aid of Northwest Texas's withdrawal as your attorney, you may notifY Brent Schellhanuner of Legal Aid of Northwest Texas in writing of your consent to this motion. Brent Schellhanuner of Legal Aid of Northwest Texas prays that the Court enter an order discharging him as attorney of record for ROBIN NICOLE WADE. Respectfully submitted, Legal Aid Of NorthWest Texas 600 E. Weatherford St. Fort Worth, Texas 76102 Tel: (817) 339-5305 Fax: (817) 877-0804 PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL In the Maner ofthe Marriage of Robin Wade and Daniel Wade and in the Interest of the Wade Page2 ' . '""~:'~~ I'lrentSCheiihammer Of Legal Aid of Northwest Texas State Bar No. 24029827 E-Mail: Schellhammerb@lanwt.org Attorney for ROBIN NICOLE WADE Notice of Hearing IJ-ei..lu.AJ }- ·tfau The above motion is set for hearing on ~{ ti!;~ at~B'b hin. in the 360th District Court of Tarrant County, Texas. SIGNED on :AO dZQI ' Certificate of Conference and Certificate of Service A conference was not held with the Respondent, DANIEL ALLEN WADE, on the merits of this motion because he is pro se and a hearing is necessary for the Court to give consent to the relief requested in the motion. I certify that a true copy of the above was served on each attorney of record or party in ~=-o wiili""' T= Rill~ ofCi"il l'ro«d~ _/ Brent Schellhammer of Legal Aid of Northwest Texas Attorney for ROBIN NICOLE WADE PETITIONER'S MOTION FOR WITHDRAWAL OF COUNSEL In the Matter of the Marriage ofRobin Wade and Daniel Wade md in the Interest of the Wade Page3