On May 03, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
C&R Construction & Roofing,
and
Barrera, Eddie,
Bermudez, Pedro,
Sanchez, Jessica,
for All Other Civil Cases (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
4/17/2024 1:59 PM
Hidalgo County District Clerks
Reviewed By: Rubie Cantu
CAUSE NO. C-1605-22-B
C&R CONSTRUCTION & ROOFING § IN THE DISTRICT COURT
Plaintiff, §
§
V. §
§
EDDIE BARRERA AND §
JESSICA SANCHEZ § 93rd JUDICIAL DISTRICT
Defendants. §
§
V. §
§
PEDRO BERMUDEZ AND §
PEDRO BERMUDEZ, JR. § HIDALGO COUNTY, TEXAS
MOTION TO WITHDRAW AS COUNSEL OF RECORD
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Robert R. Flores, Attorney for Defendants/Counter-Defendants C&R
Construction & Roofing, and hereby respectfully moves this Honorable Court to permit the
withdrawal of counsel of record for Defendants/Counter-Defendants, for the following just and
substantial reasons:
I.
Since the last hearing convened in November of 2023, it has regrettably become evident
that the client, C&R Construction & Roofing, has demonstrated a pattern of non-responsiveness
and failure to engage in substantive communication with this legal office.
II.
Despite diligent efforts by counsel to establish and maintain open lines of communication
with the client, including multiple attempts through telephone calls, electronic mail, and written
correspondence, C&R Construction & Roofing has failed to reciprocate or provide essential
feedback and instruction necessary for the advancement of their legal interests in this matter.
Electronically Filed
4/17/2024 1:59 PM
Hidalgo County District Clerks
Reviewed By: Rubie Cantu
III.
In light of the ongoing lack of responsiveness and cooperation from C&R Construction &
Roofing, it has become impracticable and untenable for counsel to effectively discharge their
professional duties in representing the interests of C&R Construction & Roofing in this
litigation.
WHEREFORE, premises considered, Robert R. Flores respectfully prays that this
Honorable Court grant the Motion to Withdraw as Counsel of Record for Defendants/Counter-
Defendants, C&R Construction & Roofing, and further requests such other relief, both in law
and equity, to which counsel may be entitled.
Respectfully submitted,
ROBERT R. FLORES, P.C.
612 West Nolana Avenue, Suite 310
McAllen, Texas 78504
Tel: (956) 329-1099
Fax: (956) 790-0297
Email: robert@rrfloreslaw.com
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that on this day, a true and correct copy of the foregoing Motion to
Withdraw as Counsel of Record has been served upon all parties of record in accordance with the
applicable provisions of the Texas Rules of Civil Procedure.
___________________
Robert R. Flores, P.C.
jgleason@penaaleczander.com
robert@rrfloreslaw.com
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.
Paralegal Flores on behalf of Robert Flores
Bar No. 24071887
paralegal@rrfloreslaw.com
Envelope ID: 86767449
Filing Code Description: Motion to Withdraw as Attorney of Record
Filing Description:
Status as of 4/17/2024 2:18 PM CST
Associated Case Party: C&R Construction & Roofing
Name BarNumber Email TimestampSubmitted Status
Robert RayFlores robert@rrfloreslaw.com 4/17/2024 1:59:02 PM SENT
Associated Case Party: Jessica Sanchez
Name BarNumber Email TimestampSubmitted Status
JORDAN KING JORDAN.KING@KINGRGVLAW.COM 4/17/2024 1:59:02 PM SENT
James A.Gleason jgleason@penaaleczander.com 4/17/2024 1:59:02 PM SENT
Associated Case Party: Eddie Barrera
Name BarNumber Email TimestampSubmitted Status
James A.Gleason jgleason@penaaleczander.com 4/17/2024 1:59:02 PM SENT
Emely Orozco eorozco@kingrgvlaw.com 4/17/2024 1:59:02 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Selene Suarez ssuarez@penaaleczander.com 4/17/2024 1:59:02 PM SENT
Robert RFlores Law Firm receptionist@rrfloreslaw.com 4/17/2024 1:59:02 PM SENT
ROBERT RAYFLORES ROBERT@RRFLORESLAW.COM 4/17/2024 1:59:02 PM SENT
Jonathan Cantu jcantu@penaaleczander.com 4/17/2024 1:59:02 PM SENT
Anapaulina Anda aanda@penaaleczander.com 4/17/2024 1:59:02 PM SENT
Robert RFlores Law Firm paralegal@rrfloreslaw.com 4/17/2024 1:59:02 PM SENT
Eddie Barrera dachuda@gmial.com 4/17/2024 1:59:02 PM SENT
Document Filed Date
April 17, 2024
Case Filing Date
May 03, 2022
Category
All Other Civil Cases (OCA)
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Electronically Filed 4/17/2024 1:59 PM Hidalgo County District Clerks Reviewed By: Rubie Cantu CAUSE NO. C-1605-22-B C&R CONSTRUCTION & ROOFING § IN THE DISTRICT COURT Plaintiff, § § V. § § EDDIE BARRERA AND § JESSICA SANCHEZ § 93rd JUDICIAL DISTRICT Defendants. § § V. § § PEDRO BERMUDEZ AND § PEDRO BERMUDEZ, JR. § HIDALGO COUNTY, TEXAS MOTION TO WITHDRAW AS COUNSEL OF RECORD TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Robert R. Flores, Attorney for Defendants/Counter-Defendants C&R Construction & Roofing, and hereby respectfully moves this Honorable Court to permit the withdrawal of counsel of record for Defendants/Counter-Defendants, for the following just and substantial reasons: I. Since the last hearing convened in November of 2023, it has regrettably become evident that the client, C&R Construction & Roofing, has demonstrated a pattern of non-responsiveness and failure to engage in substantive communication with this legal office. II. Despite diligent efforts by counsel to establish and maintain open lines of communication with the client, including multiple attempts through telephone calls, electronic mail, and written correspondence, C&R Construction & Roofing has failed to reciprocate or provide essential feedback and instruction necessary for the advancement of their legal interests in this matter. Electronically Filed 4/17/2024 1:59 PM Hidalgo County District Clerks Reviewed By: Rubie Cantu III. In light of the ongoing lack of responsiveness and cooperation from C&R Construction & Roofing, it has become impracticable and untenable for counsel to effectively discharge their professional duties in representing the interests of C&R Construction & Roofing in this litigation. WHEREFORE, premises considered, Robert R. Flores respectfully prays that this Honorable Court grant the Motion to Withdraw as Counsel of Record for Defendants/Counter- Defendants, C&R Construction & Roofing, and further requests such other relief, both in law and equity, to which counsel may be entitled. Respectfully submitted, ROBERT R. FLORES, P.C. 612 West Nolana Avenue, Suite 310 McAllen, Texas 78504 Tel: (956) 329-1099 Fax: (956) 790-0297 Email: robert@rrfloreslaw.com ATTORNEY FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that on this day, a true and correct copy of the foregoing Motion to Withdraw as Counsel of Record has been served upon all parties of record in accordance with the applicable provisions of the Texas Rules of Civil Procedure. ___________________ Robert R. Flores, P.C. jgleason@penaaleczander.com robert@rrfloreslaw.com 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. Paralegal Flores on behalf of Robert Flores Bar No. 24071887 paralegal@rrfloreslaw.com Envelope ID: 86767449 Filing Code Description: Motion to Withdraw as Attorney of Record Filing Description: Status as of 4/17/2024 2:18 PM CST Associated Case Party: C&R Construction & Roofing Name BarNumber Email TimestampSubmitted Status Robert RayFlores robert@rrfloreslaw.com 4/17/2024 1:59:02 PM SENT Associated Case Party: Jessica Sanchez Name BarNumber Email TimestampSubmitted Status JORDAN KING JORDAN.KING@KINGRGVLAW.COM 4/17/2024 1:59:02 PM SENT James A.Gleason jgleason@penaaleczander.com 4/17/2024 1:59:02 PM SENT Associated Case Party: Eddie Barrera Name BarNumber Email TimestampSubmitted Status James A.Gleason jgleason@penaaleczander.com 4/17/2024 1:59:02 PM SENT Emely Orozco eorozco@kingrgvlaw.com 4/17/2024 1:59:02 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Selene Suarez ssuarez@penaaleczander.com 4/17/2024 1:59:02 PM SENT Robert RFlores Law Firm receptionist@rrfloreslaw.com 4/17/2024 1:59:02 PM SENT ROBERT RAYFLORES ROBERT@RRFLORESLAW.COM 4/17/2024 1:59:02 PM SENT Jonathan Cantu jcantu@penaaleczander.com 4/17/2024 1:59:02 PM SENT Anapaulina Anda aanda@penaaleczander.com 4/17/2024 1:59:02 PM SENT Robert RFlores Law Firm paralegal@rrfloreslaw.com 4/17/2024 1:59:02 PM SENT Eddie Barrera dachuda@gmial.com 4/17/2024 1:59:02 PM SENT