On October 22, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Perez, Nancy Ann,
and
Perez, Lesli Nicole,
for Parent Child Relationship - Conservatorship, Access, Support
in the District Court of Montgomery County.
Preview
DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC
NO. 21-10-14737
IN THE INTEREST OF IN THE DISTRICT COURT
GERARDO LONNIE BALTIERRA AND 418TH JUDICIAL DISTRICT
NAYDEAN PEREZ
CHILDREN MONTGOMERY COUNTY, TEXAS
This Motion for Withdrawal of Counsel is brought by Sandra P. Fuentez and Shailey
, who Sandra P.
and Shailey Gupta-Brietzke requests the Court to grant permission to
withdraw as attorney this case. In support, Sandra P.
Good cause exists for withdrawal of Sandra P. Fuentez and Shailey Gupta-Brietzke
counsel, in that unable to communicate
in a manner consistent with good
A copy of this motion has been delivered to GERARDO BALTIERRA, who is
notified in writing of his right to object to this motion. GERARDO BALTIERRA
the motion. The last known address of Harlen Ave.
August 12, 2022
Motion to Withdraw-Baltierra Page 1 of 5
DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC
reporters set forth below:
Type of Date of Transcript Transcript Court Reporter
Hearing Hearing Requested? eceived? Name, Address,
Tel. No.
Hearing for 04/04/ None N/A
Habeas Corpus
Petitioner has served Respondent with the following discovery requests and the Respondent has
served the Petitioner with the following responses:
Type of Discovery Served Response Served
Request Petitioner Respondent?
Yes Yes
Interrogatories
quest for Production
Required Disclosures Service not required
Request for Admissions
Respondent has served Petitioner with the following discovery requests and
Petitioner has served Respondent with the following responses:
Type of Discovery Served Response Served
Request Respondent Petitioner
Yes Yes
Interrogatories
quest for Production
Required Disclosures Service not required
Request for Admissions
Motion to Withdraw-Baltierra Page 2 of 5
DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC
of an order granting this motion and discharging Movant of
, Movant will provide GERARDO BALTIERRA
with the originals of all of GERARDO BALTIERRA discovery responses and documents
otice t ient
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
the withdrawal of Sandra P. Fuentez and Shailey Gupta-Brietzke as your attorney, you
appear at the hearing. If you do not oppose Sandra P. Fuentez's and Shailey Gupta-
withdrawal as your attorney, you may notify Sandra P. and Shailey
and Shailey Gupta-Brietzke
Sandra P. Fuentez
Sandra P. Fuentez
State Bar No. 24045294
fuentezlaw@gmail.com
Attorney for GERARDO BALTIERRA
Motion to Withdraw-Baltierra Page 3 of 5
DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC
Shailey Gupta-Brietzke
State ar o. 24057445
file@sgblaw.com
orney for espondent
THE RISON FIRM, LLC
215 Simonton
Conroe, Texas
Tel:
Fax: -3965
William E. arrison
Stat
E-mail: c eattorney@yahoo.c
AGREED AND APPROVED TO:
ERARDO BALTIERRA
Notice of earing
ion is et aring on ___________________________ at
in 301 North Main, Suite 217, Conroe, Texas
SIGNED on
Judge or Clerk
Motion to Withdraw-Baltierra Page 4 of 5
DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC
copy of this tion for Withdrawal of Counsel
accordance with rule 21a of the Texas Rules of Civil Procedure on the following on July 1
William E. Harrison by electronic filing manager.
Terri C Mendez by electronic filing manager.
/s/ Sandra P. Fuentez
Sandra P. Fuentez
Attorney for GERARDO BALTIER
Motion to Withdraw-Baltierra Page 5 of 5
Document Filed Date
July 13, 2022
Case Filing Date
October 22, 2021
Category
Parent Child Relationship - Conservatorship, Access, Support
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Preview
DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC NO. 21-10-14737 IN THE INTEREST OF IN THE DISTRICT COURT GERARDO LONNIE BALTIERRA AND 418TH JUDICIAL DISTRICT NAYDEAN PEREZ CHILDREN MONTGOMERY COUNTY, TEXAS This Motion for Withdrawal of Counsel is brought by Sandra P. Fuentez and Shailey , who Sandra P. and Shailey Gupta-Brietzke requests the Court to grant permission to withdraw as attorney this case. In support, Sandra P. Good cause exists for withdrawal of Sandra P. Fuentez and Shailey Gupta-Brietzke counsel, in that unable to communicate in a manner consistent with good A copy of this motion has been delivered to GERARDO BALTIERRA, who is notified in writing of his right to object to this motion. GERARDO BALTIERRA the motion. The last known address of Harlen Ave. August 12, 2022 Motion to Withdraw-Baltierra Page 1 of 5 DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC reporters set forth below: Type of Date of Transcript Transcript Court Reporter Hearing Hearing Requested? eceived? Name, Address, Tel. No. Hearing for 04/04/ None N/A Habeas Corpus Petitioner has served Respondent with the following discovery requests and the Respondent has served the Petitioner with the following responses: Type of Discovery Served Response Served Request Petitioner Respondent? Yes Yes Interrogatories quest for Production Required Disclosures Service not required Request for Admissions Respondent has served Petitioner with the following discovery requests and Petitioner has served Respondent with the following responses: Type of Discovery Served Response Served Request Respondent Petitioner Yes Yes Interrogatories quest for Production Required Disclosures Service not required Request for Admissions Motion to Withdraw-Baltierra Page 2 of 5 DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC of an order granting this motion and discharging Movant of , Movant will provide GERARDO BALTIERRA with the originals of all of GERARDO BALTIERRA discovery responses and documents otice t ient 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 the withdrawal of Sandra P. Fuentez and Shailey Gupta-Brietzke as your attorney, you appear at the hearing. If you do not oppose Sandra P. Fuentez's and Shailey Gupta- withdrawal as your attorney, you may notify Sandra P. and Shailey and Shailey Gupta-Brietzke Sandra P. Fuentez Sandra P. Fuentez State Bar No. 24045294 fuentezlaw@gmail.com Attorney for GERARDO BALTIERRA Motion to Withdraw-Baltierra Page 3 of 5 DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC Shailey Gupta-Brietzke State ar o. 24057445 file@sgblaw.com orney for espondent THE RISON FIRM, LLC 215 Simonton Conroe, Texas Tel: Fax: -3965 William E. arrison Stat E-mail: c eattorney@yahoo.c AGREED AND APPROVED TO: ERARDO BALTIERRA Notice of earing ion is et aring on ___________________________ at in 301 North Main, Suite 217, Conroe, Texas SIGNED on Judge or Clerk Motion to Withdraw-Baltierra Page 4 of 5 DocuSign Envelope ID: 40AE8BCE-B04C-4128-BF44-B02C4511FCCC copy of this tion for Withdrawal of Counsel accordance with rule 21a of the Texas Rules of Civil Procedure on the following on July 1 William E. Harrison by electronic filing manager. Terri C Mendez by electronic filing manager. /s/ Sandra P. Fuentez Sandra P. Fuentez Attorney for GERARDO BALTIER Motion to Withdraw-Baltierra Page 5 of 5