FILED

15-0966
1/28/2016 5:24:23 PM
tex-8850998
SUPREME COURT OF TEXAS
BLAKE A. HAWTHORNE, CLERK

NO. 15-0966

___________________________

IN THE TEXAS SUPREME COURT

STEVEN GREGORY SLOAT, ED BRYAN, CHURCH OF SCIENTOLOGY
INTERNATIONAL, DAVID J. LUBOW AND MONTY DRAKE,
PETITIONERS
V.

MONIQUE RATHBUN,
RESPONDENT
On Petition for Review from the
Texas Court of Appeals, Third District, at Austin
Cause No. 03-14-00199-CV

UNOPPOSED MOTION FOR WITHDRAWAL OF COUNSEL FOR

RESPONDENT AND FOR LIMITED LIFT OF STAY
Counsel for Monique Rathbun file this Unopposed Motion for Withdrawal of
Counsel for Respondent and for Limited Lift of Stay, and in support thereof would
respectfully show the Court as follows:

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1.

Monique Rathbun has discharged the undersigned attorneys

without cause.

Accordingly, the undersigned attorneys seek to withdraw as

counsel for Ms. Rathbun in these proceedings.

2.

Ms. Rathbun has been notified of the filing of this motion and,

as reflected by her signature, does not oppose the relief requested herein. As set
forth in the Certificate of Conference below, no other party objects to the request
that the undersigned attorneys be allowed to withdraw.
3.

Notices to Ms. Rathbun can be mailed to 501 Sunset, Ingleside on the

Bay, Texas 78362.

4.

This case is on interlocutory appeal pursuant to sections 27.003 and

51.014 of the Texas Civil Practice and Remedies Code.

Pursuant to section

51.014(b), proceedings in the trial court are currently stayed, including proceedings
against Defendants other than Petitioners herein. Accordingly, the undersigned
counsel request that the Court lift the section 51.014(b) stay for the limited purpose
of allowing Respondents counsel to withdraw from the currently-stayed
proceedings. This request for a limited lifting of the stay is not sought for purposes
of delay, but so that justice may be served.

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WHEREFORE, Counsel for Monique Rathbun pray that this Motion be granted
and that:
1.

The counsel listed below be permitted to withdraw as counsel for

Respondent, Monique Rathbun; and

2.

The Court lift the stay imposed by section 51.014 of the Texas Civil
Practice and Remedies Code for the limited purpose of allowing the
counsel listed below to file and have heard a motion to withdraw as
counsel in the trial court.

Respectfully submitted,
PULMAN, CAPPUCCIO,
PULLEN, BENSON & JONES, LP
2161 NW Military Highway, Suite 400
San Antonio, Texas 78213
www.pulmanlaw.com
(210) 222-9494 Telephone
(210) 892-1610 Facsimile
By: /s/ Leslie Sara Hyman
Elliott S. Cappuccio
Texas State Bar No. 24008419
ecappuccio@pulmanlaw.com
Leslie Sara Hyman
Texas State Bar No. 00798274
lhyman@pulmanlaw.com
JEFFREY LAW FIRM
Ray B. Jeffrey
Texas State Bar Number 10613700
2631 Bulverde Road, Suite 105
Bulverde, Texas 78163
(830) 438-8935 Telephone
(830) 438-4958 Facsimile
rjeffrey@sjmlawyers.com

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THE WIEGAND LAW FIRM, P.C.

Marc F. Wiegand
Texas State Bar No. 21431300
434 North Loop 1604 West, Suite 2201
San Antonio, Texas 78232
(210) 998-3289 Telephone
(210) 998-3179 Facsimile
marc@wiegandlawfirm.com
ATIORNEYS FOR RESPONDENT
MONIQUE RATHBUN

APPROVED:

..

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CERTIFICATE OF CONFERENCE
I certify that on January 28, 2016, I conferred with counsel for Petitioners
regarding the subject matter of this Motion and that Petitioners do not oppose the
relief requested.
/s/ Leslie Sara Hyman

CERTIFICATE OF SERVICE
I certify that on the 28th day of January 2016, the foregoing Unopposed Motion
for Withdrawal of Counsel for Respondent and for Limited Lift of Stay has been
electronically filed with the Clerk of Court using the eFile.TXCourts.gov
electronic filing system, which will send notification of the filing to the following:
Jonathan H. Hull
jhull@reaganburrus.com
Ashley B. Bowen
abowenl@reaganburrus.com
Reagan Burrus
401 Main Plaza, Suite 200
New Braunfels, Texas 78130

Eric M. Lieberman
rlieberman@rbskl.com
Rabinowitz, Boudin, Standard, Krinsky
& Lieberman PC
45 Broadway, Suite 1700
New York, New York 10006

Thomas S. Leatherbury
tleatherbury@velaw.com
Marc A. Fuller
mfuller@velaw.com
Vinson & Elkins LLP
2001 Ross Avenue, Suite 3700
Dallas, Texas 75201

Stephanie S. Bascon
sbascon@att.net
Law Office of Stephanie S. Bascon
PLLC
297 West San Antonio Street
New Braunfels, Texas 78130

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Gary D. Sarles
gsarles@sarleslaw.com
O. Paul Dunagan
dunagan@sarleslaw.com
900 Jackson Street, Suite 370
Dallas, Texas 75202

Douglas W. Alexander
dalexander@adjtlaw.com
Alexander Dubose Jefferson &
Townsend LLP
515 Congress Avenue, Suite 2350
Austin, Texas 78701-3562

/s/ Leslie Sara Hyman

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