Document for Marcos Antonio Hernandez, Veronica Gonzalez Individually and A Next Friend to Melanie Hernandez (Minor) and Derek Hernandez (Minor) VS. Veronica Gonzalez, City of Alamo, Texas

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Preview
                                Electronically Filed
                                                                                   5/26/2022 4:10 PM
                                                                                   Hidalgo County District Clerks
                                                                                   Reviewed By: Armando Hervert




                                    CAUSE NO. C-4198-21-F

  MARCOS ANTONIO HERNANDEZ,                        §     IN THE DISTRICT COURT
  VERONICA GONZALEZ                                §
  INDIVIDUALLY AND AS NEXT                         §
  FRIEND TO MELANIE                                §
  HERNANDEZ (MINOR) AND                            §
  DEREK HERNANDEZ (MINOR)                          §
        PLAINTIFFS                                 §     332ND JUDICIAL DISTRICT
                                                   §
  V.                                               §
                                                   §
  CITY OF ALAMO, TEXAS, AND                        §
  HIDALGO COUNTY SHERIFF’S                               OF HIDALGO COUNTY, TEXAS
  OFFICE
       DEFENDANTS

                         UNOPPOSED MOTION TO SUBSTITUTE
                       PRESTON HENRICHSON AS COUNSEL FOR
              HIDALGO COUNTY SHERIFF’S OFFICE AND FOR WITHDRAWAL OF
                  RICARDO RODRIGUEZ, JR, AND ASSOCIATED COUNSEL

 TO THE HONORABLE JUDGE OF SAID COURT:

        Defendant, Hidalgo County Sheriff’s Office, and Hidalgo County, file this Unopposed

 Motion to Substitute Preston Henrichson as its Counsel in this matter and for Withdrawal of

 Ricardo Rodriguez, Jr., and his associated counsel of record for such Defendant, and in support

 thereof would respectfully show the court as follows:

         1.     Ricardo Rodriguez, Jr. and his associated counsel, Jaclyn M. Erasmus, Josephine

 Ramirez-Solis, and Victor M. Garza, are currently the attorneys of record for Defendant Hidalgo

 County, called “Hidalgo County Sheriff’s Office” herein, and wish to withdraw as counsel herein

 because the Hidalgo County Commissioner’s Court has employed the undersigned Preston

 Henrichson to represent Hidalgo County and its Sheriff’s Office in this matter.




UNOPPOSED MOTION TO SUBSTITUTE COUNSEL FOR DEFENDANT
                                                                                           1|Page
                                                                                       Electronically Filed
                                                                                       5/26/2022 4:10 PM
                                                                                       Hidalgo County District Clerks
                                                                                       Reviewed By: Armando Hervert



        2.         Accordingly, Defendant, Hidalgo County A/K/A Hidalgo County Sheriff’s Office

 respectfully requests that the following attorney to be substituted as its counsel of in this matter:


                                  PRESTON HENRICHSON
                                  Texas Bar No. 09477000
                                  HENRICHSON LAW PLLC
                                  222 West Cano
                                  Edinburg, TX 78539
                                  Telephone: (956) 383-3535
                                  Facsimile: (956) 383-3585
                                  E-Mail:Eservices@henrichsonlaw.com

        3.         Thus, good cause exists for the Court to grant this Motion for the Substitution of

 Preston Henrichson as Counsel for Defendant, Hidalgo County A/K/A Hidalgo County Sheriff’s

 Office and for withdrawal of Ricardo Rodriguez, Jr. and his associated counsel, Jaclyn M.

 Erasmus, Josephine Ramirez-Solis, and Victor M. Garza, as such Defendant’s counsel of record

 pursuant to Rule 10 of the Texas Rules of Civil Procedure.

        4.         This motion is not sought for delay, but for the best interest of all parties and for

 good cause pursuant to Rule 10 of the Texas Rules of Civil Procedure.

        5.         WHEREFORE, PREMISES CONSIDERED, Defendant respectfully requests that

 the Court grant this Motion to Substitute Preston Henrichson as counsel and for the Withdrawal of

 Ricardo Rodriguez, Jr. and his associated counsel, Jaclyn M. Erasmus, Josephine Ramirez-Solis,

 and Victor M. Garza, as Counsel for Defendant, Hidalgo County A/K/A Hidalgo County Sheriff’s

 Office, herein.




UNOPPOSED MOTION TO SUBSTITUTE COUNSEL FOR DEFENDANT
                                                                                               2|Page
                                                                                      Electronically Filed
                                                                                      5/26/2022 4:10 PM
                                                                                      Hidalgo County District Clerks
                                                                                      Reviewed By: Armando Hervert



                                               Respectfully submitted,


                                              By: /s/ Preston Henrichson
                                              PRESTON HENRICHSON
                                              Texas Bar No. 09477000
                                              HENRICHSON LAW PLLC
                                              222 West Cano
                                              Edinburg, TX 78539
                                              Telephone: (956) 383-3535
                                              Facsimile: (956) 383-3585
                                              E-Mail:Eservices@henrichsonlaw.com




                                  CERTIFICATE OF SERVICE

         I certify that on May 26, 2022, a true and correct copy of the forgoing Unopposed Motion to
 Substitute and Withdraw as Counsel was forwarded via E-Service filing on all parties and counsel
 of record.


                                              By: /s/ Preston Henrichson
                                                     Preston Henrichson


                               CERTIFICATE OF CONFERENCE

         I hereby certify that a conference was held with Victor M. Garza on behalf of Ricardo
 Rodriguez, Jr., and his associated counsel, Rosemary Conrad-Sandoval counsel for Defendant, and
 Stephen P. Carrigan, counsel for Plaintiffs, regarding the merits of this Motion. All parties expressly
 agree tothe submission of the same as unopposed.


                                              By: /s/ Preston Henrichson
                                                     Preston Henrichson




UNOPPOSED MOTION TO SUBSTITUTE COUNSEL FOR DEFENDANT
                                                                                              3|Page
                         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.

Amada Rendon on behalf of Preston Henrichson
Bar No. 09477000
Amada@henrichsonlaw.com
Envelope ID: 64902882
Status as of 5/27/2022 8:24 AM CST

Associated Case Party: City of Alamo, Texas

Name                       BarNumber   Email                 TimestampSubmitted    Status

Rosemary Conrad-Sandoval               rsandoval@rofllp.com 5/26/2022 4:10:29 PM   SENT



Case Contacts

Name                   BarNumber Email                                  TimestampSubmitted     Status

Jaclyn Erasmus         24102786    jaclyn.erasmus@da.co.hidalgo.tx.us   5/26/2022 4:10:29 PM   SENT

Wendy Watson                       wwatson@ccatriallaw.com              5/26/2022 4:10:29 PM   SENT

Renee Kubik                        rkubik@ccatriallaw.com               5/26/2022 4:10:29 PM   SENT

STEPHEN P.CARRIGAN                 SCARRIGAN@CCATRIALLAW.COM 5/26/2022 4:10:29 PM              SENT

Preston Henrichson                 eservices@henrichsonlaw.com          5/26/2022 4:10:29 PM   SENT