Document for Veronica Woodard VS. GADY EVANY RODRIGUEZ, JUAN DANIEL QUINTO-VASQUEZ, GADY QUINTO, OFFICER E. SUAREZ

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                                Electronically Filed
                                                                                   2/12/2024 10:07 AM
                                                                                   Hidalgo County District Clerks
                                                                                   Reviewed By: Claudia Rangel


                                   CAUSE NO. C-2941-23-G

VERONICA WOODARD                                 §            IN THE DISTRICT COURT
                                                 §
IN THE MATTER OF THE DEATH                       §           370TH JUDICIAL DISTRICT
                                                 §
OF ANDREW CAMERON WOODARD                        §           HIDALGO COUNTY, TEXAS

                MOTION TO WITHDRAW AS ATTORNEY OF RECORD

TO THE HONORABLE JUDGE OF SAID COURT:

       COMES NOW, Attorney Noe Robles, counsel of record for the petitioner, Veronica

Woodard, in the above-referenced cause, and hereby submits this Motion to Withdraw as

Counsel of Record based on the following:

                           I.      Failure to Maintain Communication:

       Despite diligent efforts to maintain communication with the client, Veronica Woodard,

there has been a consistent failure on her part to respond to phone calls and messages from my

office, impeding the progress of legal proceedings. Numerous attempts have been made to reach

Ms. Woodard through various means of communication, including phone calls, emails, and

letters, all of which have gone unanswered.

                                   II.    Non-Payment of Costs:

       Ms. Woodard has failed to fulfill financial obligations, specifically the outstanding

balance owed to Ace Court Reporting in the amount of $1674.70 for the deposition conducted on

November 10, 2023, as ordered by this Honorable Court. Despite multiple reminders and

requests for payment, Ms. Woodard has not provided any indication of intent to settle this debt.

                                   III.   Conflict of Personality:

       Additionally, there exists a significant conflict of personality between the client and

myself, which has hindered our ability to effectively collaborate on this matter and has created an
                                                                                     Electronically Filed
                                                                                     2/12/2024 10:07 AM
                                                                                     Hidalgo County District Clerks
                                                                                     Reviewed By: Claudia Rangel


untenable working relationship. This conflict has resulted in difficulties in communication and

cooperation, making it increasingly challenging to provide effective representation.

                       IV.     Inability to Provide Effective Representation:

       Given the aforementioned circumstances, it has become clear that continued

representation of Ms. Woodard is not feasible, and it is in the best interest of both parties to

terminate our professional relationship. Without adequate communication, payment of

outstanding costs, and resolution of the conflict of personality, I am unable to effectively

represent Ms. Woodard in this matter.

       WHEREFORE, premises considered, Attorney Noe Robles respectfully requests that

this Honorable Court grant leave for withdrawal as counsel of record for Veronica Woodard.

                                                               Respectfully,

                                                               /s/Noe Robles
                                                               Noe Robles

                                                               Law Office of Noe Robles
                                                               23331 Tamm Lane
                                                               Harlingen, TX 78552
                                                               Phone: 956-440-8200
                                                               Fax: 956-440-8205
                                                               NRoblesLawOffice@aol.com

                                 CERTIFICATE OF SERVICE

       I, Noe Robles hereby certify that a true and correct copy of the foregoing Motion to

Withdraw as Counsel of Record has been furnished to the Hidalgo County District Clerk via

electronic transmission on February 12, 2024, and by mail on the same day to Veronica Woodard

as follows:

Veronica Woodard
121 E Quamasia Ave #218,                   /s/ Noe Robles
Mission, TX 78504                          Noe Robles
                         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.

Noe Robles
Bar No. 17118250
NRoblesLawOffice@aol.com
Envelope ID: 84390279
Filing Code Description: Motion (No Fee)
Filing Description: Motion to WIthdraw as Attorney of Record
Status as of 2/12/2024 11:59 AM CST

Case Contacts

Name             BarNumber   Email                            TimestampSubmitted   Status

DISTRICT CLERK               DISTRICTCLERK@CO.HIDALGO.TX.US 2/12/2024 10:07:46 AM SENT

N ROBLES                     NROBLESLAWOFFICE@AOL.COM         2/12/2024 10:07:46 AM ERROR