On March 20, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
and
for AG-Motion To Revoke
in the District Court of Smith County.
Preview
Electronically Filed
7/30/2020 12:23 PM
Penny Clarkston, Smith County District Clerk
Reviewed By: Donna Lee
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA
CAUSE NO. 15-5145-D
IN THE INTEREST OF § IN THE 321ST DISTRICT COURT
§
H.D.F., AND T.R.F., § OF
§
CHILDREN § SMITH COUNTY, TEXAS
MOTION TO WITHDRAW AS COUNSEL
This Motion for Withdrawal of Counsel is brought by Emily Jo Ivy, who was
appointed as attorney of record for Joshua Farrer. Emily Jo Ivy requests the Court to
grant her permission to withdraw as attorney for Joshua Farrer in this case. In support,
Emily Jo Ivy shows:
Type of Date of Transcript Transcript Court Reporter’s
Hearing Hearing Requested? Received? Name, Address,
Tel. No.
Child Support 09.16.2019 No No Laura Payne, 100
N Broadway Ave.,
Tyler, Texas
75702,
903.590.1603.
Child Support 06.22.2020 No No Laura Payne, 100
N Broadway Ave.,
Tyler, Texas
75702,
903.590.1603.
Warrant 06.24.2020
Issued by 321 st
Motion to 08.17.2020
Withdraw as
Counsel
Good cause exists for withdrawal of Emily Jo Ivy as counsel, in that she is unable
to effectively communicate with Joshua Farrer in a manner consistent with good
attorney-client relations. Emily Jo Ivy has been unable to contact Joshua Farrer directly
Cause No. 15-5145-D; ITIO H.D.F., and T.R.F., Children 1
Motion to Withdraw as Counsel
since on March 25, 2020 through email. Emily Jo Ivy has made attempts to contact
Joshua Farrer through email, telephone, and mail since March 25th, but has been unable
to reach Joshua Farrer.
A file marked copy of this motion will been delivered to Joshua Farrer, who is
hereby notified in writing of his right to object to this motion. Joshua Farrer has not
consented to this motion. The last known address of Joshua Farrer is 3778 FM 1519 W.
Pittsburg, Texas, 75686. This motion and Notice of Setting will be delivered to Joshua
Farrer through both certified mail and regular mail.
Joshua Farrer does have an active warrant out for his arrest, issued
by the 321st District Court due to his non-appearance at the June 22, 2020
hearing.
There is not a pending Final Trial set for this case.
No requests for discovery have been served by either party in this case.
NOTICE TO CLIENT
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 contest the withdrawal of Emily Jo Ivy as your attorney, you should not sign
below. If you do not wish to oppose Emily Jo Ivy’s withdrawal as your attorney, you may
notify Emily Jo Ivy and this Court in writing of your consent to this motion by signing
below and returning said document with signature to Emily Jo Ivy.
Emily Jo Ivy prays that the Court enter an order discharging her as attorney of
record for Joshua Farrer.
Respectfully submitted,
Cause No. 15-5145-D; ITIO H.D.F., and T.R.F., Children 2
Motion to Withdraw as Counsel
Ivy Law Office, PLLC
100 E Ferguson Street Suite 610
Tyler, Texas 75702
info@ivylawoffice.net
O: 903.989.7097
F: 903.989.7096
Emily Jo Ivy
State Bar No. 24104005
Attorney for Joshua Farrer
AGREED TO AND APPROVED:
________________________________
Joshua Farrer
CERTIFICATE OF SERVICE
U
This is to certify that on _July 30, 2020______, a true and correct copy of the
U
above and foregoing document was served on Joshua Farrer (Regular Mail and CM) in
accordance with Rule 21a of the Texas Rules of Civil Procedure.
Emily Jo Ivy
Attorney for Joshua Farrer, Respondent
Cause No. 15-5145-D; ITIO H.D.F., and T.R.F., Children 3
Motion to Withdraw as Counsel
Document Filed Date
July 30, 2020
Case Filing Date
March 20, 2015
Category
AG-Motion To Revoke
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Preview
Electronically Filed 7/30/2020 12:23 PM Penny Clarkston, Smith County District Clerk Reviewed By: Donna Lee NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA CAUSE NO. 15-5145-D IN THE INTEREST OF § IN THE 321ST DISTRICT COURT § H.D.F., AND T.R.F., § OF § CHILDREN § SMITH COUNTY, TEXAS MOTION TO WITHDRAW AS COUNSEL This Motion for Withdrawal of Counsel is brought by Emily Jo Ivy, who was appointed as attorney of record for Joshua Farrer. Emily Jo Ivy requests the Court to grant her permission to withdraw as attorney for Joshua Farrer in this case. In support, Emily Jo Ivy shows: Type of Date of Transcript Transcript Court Reporter’s Hearing Hearing Requested? Received? Name, Address, Tel. No. Child Support 09.16.2019 No No Laura Payne, 100 N Broadway Ave., Tyler, Texas 75702, 903.590.1603. Child Support 06.22.2020 No No Laura Payne, 100 N Broadway Ave., Tyler, Texas 75702, 903.590.1603. Warrant 06.24.2020 Issued by 321 st Motion to 08.17.2020 Withdraw as Counsel Good cause exists for withdrawal of Emily Jo Ivy as counsel, in that she is unable to effectively communicate with Joshua Farrer in a manner consistent with good attorney-client relations. Emily Jo Ivy has been unable to contact Joshua Farrer directly Cause No. 15-5145-D; ITIO H.D.F., and T.R.F., Children 1 Motion to Withdraw as Counsel since on March 25, 2020 through email. Emily Jo Ivy has made attempts to contact Joshua Farrer through email, telephone, and mail since March 25th, but has been unable to reach Joshua Farrer. A file marked copy of this motion will been delivered to Joshua Farrer, who is hereby notified in writing of his right to object to this motion. Joshua Farrer has not consented to this motion. The last known address of Joshua Farrer is 3778 FM 1519 W. Pittsburg, Texas, 75686. This motion and Notice of Setting will be delivered to Joshua Farrer through both certified mail and regular mail. Joshua Farrer does have an active warrant out for his arrest, issued by the 321st District Court due to his non-appearance at the June 22, 2020 hearing. There is not a pending Final Trial set for this case. No requests for discovery have been served by either party in this case. NOTICE TO CLIENT 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 contest the withdrawal of Emily Jo Ivy as your attorney, you should not sign below. If you do not wish to oppose Emily Jo Ivy’s withdrawal as your attorney, you may notify Emily Jo Ivy and this Court in writing of your consent to this motion by signing below and returning said document with signature to Emily Jo Ivy. Emily Jo Ivy prays that the Court enter an order discharging her as attorney of record for Joshua Farrer. Respectfully submitted, Cause No. 15-5145-D; ITIO H.D.F., and T.R.F., Children 2 Motion to Withdraw as Counsel Ivy Law Office, PLLC 100 E Ferguson Street Suite 610 Tyler, Texas 75702 info@ivylawoffice.net O: 903.989.7097 F: 903.989.7096 Emily Jo Ivy State Bar No. 24104005 Attorney for Joshua Farrer AGREED TO AND APPROVED: ________________________________ Joshua Farrer CERTIFICATE OF SERVICE U This is to certify that on _July 30, 2020______, a true and correct copy of the U above and foregoing document was served on Joshua Farrer (Regular Mail and CM) in accordance with Rule 21a of the Texas Rules of Civil Procedure. Emily Jo Ivy Attorney for Joshua Farrer, Respondent Cause No. 15-5145-D; ITIO H.D.F., and T.R.F., Children 3 Motion to Withdraw as Counsel