On April 29, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Cadena, Juan Norberto,
and
Kebo Oil And Gas, Inc,
for Injury or Damage - Other (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
4/3/2024 11:13 AM
Hidalgo County District Clerks
Reviewed By: Lesley Martinez
CAUSE NO. C-1637-21-J
JUAN NORBETO CADENA § IN THE 430TH JUDICIAL
PLAINTIFF §
§
V. § DISTRICT COURT OF
§
KEBO OIL AND GAS, INC. §
DEFENDANT § HIDALGO COUNTY, TEXAS
MOTION FOR WITHDRAWAL OF COUNSEL, JOHN P. RILEY
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, Movant, DESOUZA INJURY LAWYERS, Attorney of Record for the
Plaintiff in the above styled and numbered cause, who would file this Motion to
withdraw counsel, JOHN P. RILEY, in the present cause, and show unto the Court as
follows:
I.
Movant has identified certain obstacles to continue representation in this
matter, which thereby prevents JOHN P. RILEY from further representation of the
Plaintiff. This consideration reduces the ability of JOHN P. RILEY to provide
adequate representation to Plaintiff. Movant, DESOUZA INJURY LAWYERS, will
continue their representation of Plaintiff.
II.
There is good cause to grant the motion to withdraw of JOHN P. RILEY, only,
as counsel of record.
1
Electronically Filed
4/3/2024 11:13 AM
Hidalgo County District Clerks
Reviewed By: Lesley Martinez
III.
The granting of this Motion to Withdraw will not jeopardize the rights of
Plaintiff. The requested withdrawal is not for the purposes of delay.
WHEREFORE, PREMISES CONSIDERED, Movant prays that this Court allow the
withdrawal of counsel, JOHN P. RILEY, only, and that JOHN P. RILEY, only, be
released from further obligation or duty to Plaintiff as his attorney of record.
RESPECTFULLY SUBMITTED,
DESOUZA INJURY LAWYERS
4047 NACO PERRIN SUITE 100
SAN ANTONIO, TEXAS 78217
210/ 714-4215 – PHONE
210/496-0060 – FACSIMILE
BY: /S/ Jason F. DeSouza
JASON F. DESOUZA
STATE BAR NO.: 24073255
jason@jfdlawfirm.com
BY: /S/ Jorge L. Alvarez
JORGE L. ALVAREZ
STATE BAR NO.: 24133590
jorge@jfdlawfirm.com
ATTORNEYS FOR PLAINTIFF
2
Electronically Filed
4/3/2024 11:13 AM
Hidalgo County District Clerks
Reviewed By: Lesley Martinez
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the above and foregoing
instrument was duly served in accordance with the TEXAS RULES OF CIVIL PROCEDURE
on April 3, 2024 upon the following:
VIA E SERVICE: lwarren@namanhowell.com; epatterson@namanhowell.com
LARRY D. WARREN
STATE BAR NO. 20888450
EVAN F. PATTERSON
STATE BAR NO. 24098232
NAMAN HOWELL
10001 REUNION PLACE, SUITE 600
SAN ANTONIO, TEXAS 78216
TELEPHONE: (210) 731-6350
FACSIMILE: (210) 785-2950
ATTORNEYS FOR DEFENDANT
BY: /S/ Jason F. DeSouza
JASON F. DESOUZA
3
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.
DeSouza Injury Lawyers
Bar No. 24073255
jason@jfdlawfirm.com
Envelope ID: 86237242
Filing Code Description: Motion (No Fee)
Filing Description: Motion for Withdrawal of Counsel- John P. Riley
Status as of 4/4/2024 2:37 PM CST
Associated Case Party: JUANNORBERTOCADENA
Name BarNumber Email TimestampSubmitted Status
Jason DeSouza scheduling@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT
Michelle Roberson michelle@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT
JASON FDESOUZA jason@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Sara Gonzalez sara@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT
Commercial Scheduling Comm_scheduling@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT
JORGE LALVAREZ JORGE@JFDLAWFIRM.COM 4/3/2024 11:13:48 AM SENT
ADRIANA SOLIS ASOLIS@NAMANHOWELL.COM 4/3/2024 11:13:48 AM SENT
Associated Case Party: KEBO OIL AND GAS, INC
Name BarNumber Email TimestampSubmitted Status
LARRY WARREN lwarren@namanhowell.com 4/3/2024 11:13:48 AM SENT
EVAN FPATTERSON EPATTERSON@NAMANHOWELL.COM 4/3/2024 11:13:48 AM SENT
Document Filed Date
April 03, 2024
Case Filing Date
April 29, 2021
Category
Injury or Damage - Other (OCA)
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Electronically Filed 4/3/2024 11:13 AM Hidalgo County District Clerks Reviewed By: Lesley Martinez CAUSE NO. C-1637-21-J JUAN NORBETO CADENA § IN THE 430TH JUDICIAL PLAINTIFF § § V. § DISTRICT COURT OF § KEBO OIL AND GAS, INC. § DEFENDANT § HIDALGO COUNTY, TEXAS MOTION FOR WITHDRAWAL OF COUNSEL, JOHN P. RILEY TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, Movant, DESOUZA INJURY LAWYERS, Attorney of Record for the Plaintiff in the above styled and numbered cause, who would file this Motion to withdraw counsel, JOHN P. RILEY, in the present cause, and show unto the Court as follows: I. Movant has identified certain obstacles to continue representation in this matter, which thereby prevents JOHN P. RILEY from further representation of the Plaintiff. This consideration reduces the ability of JOHN P. RILEY to provide adequate representation to Plaintiff. Movant, DESOUZA INJURY LAWYERS, will continue their representation of Plaintiff. II. There is good cause to grant the motion to withdraw of JOHN P. RILEY, only, as counsel of record. 1 Electronically Filed 4/3/2024 11:13 AM Hidalgo County District Clerks Reviewed By: Lesley Martinez III. The granting of this Motion to Withdraw will not jeopardize the rights of Plaintiff. The requested withdrawal is not for the purposes of delay. WHEREFORE, PREMISES CONSIDERED, Movant prays that this Court allow the withdrawal of counsel, JOHN P. RILEY, only, and that JOHN P. RILEY, only, be released from further obligation or duty to Plaintiff as his attorney of record. RESPECTFULLY SUBMITTED, DESOUZA INJURY LAWYERS 4047 NACO PERRIN SUITE 100 SAN ANTONIO, TEXAS 78217 210/ 714-4215 – PHONE 210/496-0060 – FACSIMILE BY: /S/ Jason F. DeSouza JASON F. DESOUZA STATE BAR NO.: 24073255 jason@jfdlawfirm.com BY: /S/ Jorge L. Alvarez JORGE L. ALVAREZ STATE BAR NO.: 24133590 jorge@jfdlawfirm.com ATTORNEYS FOR PLAINTIFF 2 Electronically Filed 4/3/2024 11:13 AM Hidalgo County District Clerks Reviewed By: Lesley Martinez CERTIFICATE OF SERVICE This will certify that a true and correct copy of the above and foregoing instrument was duly served in accordance with the TEXAS RULES OF CIVIL PROCEDURE on April 3, 2024 upon the following: VIA E SERVICE: lwarren@namanhowell.com; epatterson@namanhowell.com LARRY D. WARREN STATE BAR NO. 20888450 EVAN F. PATTERSON STATE BAR NO. 24098232 NAMAN HOWELL 10001 REUNION PLACE, SUITE 600 SAN ANTONIO, TEXAS 78216 TELEPHONE: (210) 731-6350 FACSIMILE: (210) 785-2950 ATTORNEYS FOR DEFENDANT BY: /S/ Jason F. DeSouza JASON F. DESOUZA 3 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. DeSouza Injury Lawyers Bar No. 24073255 jason@jfdlawfirm.com Envelope ID: 86237242 Filing Code Description: Motion (No Fee) Filing Description: Motion for Withdrawal of Counsel- John P. Riley Status as of 4/4/2024 2:37 PM CST Associated Case Party: JUANNORBERTOCADENA Name BarNumber Email TimestampSubmitted Status Jason DeSouza scheduling@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT Michelle Roberson michelle@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT JASON FDESOUZA jason@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Sara Gonzalez sara@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT Commercial Scheduling Comm_scheduling@jfdlawfirm.com 4/3/2024 11:13:48 AM SENT JORGE LALVAREZ JORGE@JFDLAWFIRM.COM 4/3/2024 11:13:48 AM SENT ADRIANA SOLIS ASOLIS@NAMANHOWELL.COM 4/3/2024 11:13:48 AM SENT Associated Case Party: KEBO OIL AND GAS, INC Name BarNumber Email TimestampSubmitted Status LARRY WARREN lwarren@namanhowell.com 4/3/2024 11:13:48 AM SENT EVAN FPATTERSON EPATTERSON@NAMANHOWELL.COM 4/3/2024 11:13:48 AM SENT