Upload
others
View
4
Download
0
Embed Size (px)
Citation preview
NOT-SO-SECRET INSIGHTS FOR SUCCESS IN THE EASTERN DISTRICT
Author & Speaker: LIZ BOYDSTON
Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP
2200 Ross Avenue, Suite 2800 Dallas, Texas 75201
Speakers:
ROBERT P. COLWELL, Dallas Law Clerk to Judge Harlin D. Hale
(214) 753-2017 [email protected]
ALLEN M. DEBARD, San Antonio
Law Clerk to Judge Ronald King (210) 472-6720
CATHY TA, Houston Law Clerk to Judge Marvin Isgur
(713) 250-5372 [email protected]
State Bar of Texas 27th ANNUAL ADVANCED
BUSINESS BANKRUPTCY COURSE October 1-2, 2009
Houston
CHAPTER 14
LIZ BOYDSTON
Fulbright & Jaworski, L.L.P. 2200 Ross Avenue, Suite 2800
Dallas, Texas 75201 214-855-7475
BIOGRAPHICAL INFORMATION EDUCATION J.D., cum laude, Southern Methodist University Dedman School of Law
B.A., magna cum laude graduate of the University Scholars Program, Baylor University
PROFESSIONAL ACTIVITIES & MEMBERSHIPS Associate, Fulbright & Jaworski L.L.P., Dallas, Texas – Bankruptcy and Insolvency
State Bar of Texas
DFW Association of Young Bankruptcy Lawyers (DAYBL)
Dallas Association of Young Lawyers (DAYL)
Moot Court Coach
CIVIC INVOLVEMENT Dallas Volunteer Attorney Program (DVAP)
Big Brothers Big Sisters of Dallas
PRIOR EXPERIENCE Before joining Fulbright & Jaworski L.L.P. in the Bankruptcy and Insolvency group, Liz served as law clerk to Chief Bankruptcy Judge Bill Parker in the U.S. Bankruptcy Court for the Eastern District of Texas from September 2007 to April 2009.
Rob Colwell Career Law Clerk to the Honorable Harlin D. “Cooter” Hale
U.S. Bankruptcy Court for the Northern District of Texas 1100 Commerce Street - Room 1254
Dallas, Texas 75242-1496 214/753-2017 [email protected] BACKGROUND EDUCATION AND EXPERIENCE Rob was born in Dallas, and currently lives in Grand Prairie, Texas. Rob has been married to his wonderful wife, Tina, for fifteen years. They currently spend most of their free time enjoying their two children, Emma and Pearce, ages 10 and 8. Before practicing law, Rob earned a B.B.A. in Accounting and a B.S. in Economics, with an emphasis in International Economics from Texas Christian University in Fort Worth in 1991, and a J.D. from Southern Methodist University in Dallas in 1994. After law school, Rob practiced for a year before starting a two-year judicial clerkship for Judge Harold C. Abramson, and eventually became Judge Abramson’s Career Law Clerk for eight years. In 2003, after Judge Abramson retired, Rob practiced law for a year as a contract attorney for Winstead, P.C., in the area of bankruptcy and commercial litigation, and then returned to the bankruptcy court to work for Judge Harlin D. “Cooter” Hale. For the last five years, Rob has what he considers the best job in the legal profession as Judge Hale’s Career Law Clerk. Rob has worn many hats during his thirteen plus years at the bankruptcy court. During the implementation of CM/ECF, he was appointed by the Chief Bankruptcy Judge for the Northern District of Texas as a Member of the CM/ECF Executive Committee, and as a representative of the Court on the Attorney/Trustee Advisory Committee. He also served as the Support and Training Coordinator of the CM/ECF implementation team for the Judges and Chambers staff. He assisted in drafting the bankruptcy court’s local rules, forms, Attorney Handbook and ECF Administrative Procedures, and has advised the Clerk of Court and her deputies on various legal matters, including representing the Clerk on two separate EEO complaints pursuant to the Court’s grievance procedures. During this time he received a Special Service Award and an Outstanding Training Award. Rob is a Barrister in the John C. Ford American Inn of Court, and is a member of the Bankruptcy Section of the State Bar of Texas. He has presented papers and spoken at various bankruptcy conferences and bar association meetings.
ALLEN M. DEBARD6410 BLANCH CIRCLE
DALLAS, TEXAS 75214
214.926.2396
BIOGRAPHICAL INFORMATION
EDUCATION:
• WASHINGTON AND LEE UNIVERSITY, LEXINGTON, VIRGINIA, B.S. with SpecialAttainments in Commerce, Business Administration and Accounting, 2005.
• ST. MARY’S UNIVERSITY SCHOOL OF LAW, SAN ANTONIO, TEXAS, J.D. 2008.
PROFESSIONAL ACTIVITIES:
• Briefing Attorney to the Honorable Ronald B. King, United States Bankruptcy Courtfor the Western District of Texas, San Antonio, Division, August 2008 throughAugust 2009.
• Member, State Bar of Texas, San Antonio Young Lawyers Association, YoungTexans Against Cancer (YTAC).
HONORS:
NCAA Football Letterman, Phi Alpha Delta.Dean’s Leadership Scholarship.
CATHY TA
2400 Westheimer Road, 107E, Houston, Texas 77098 · (626) 354-6987 · [email protected]
EXPERIENCE The Honorable Chief Bankruptcy Judge Marvin Isgur, Houston, Texas
Law Clerk, Sept. 2008 - present • Primarily responsible for drafting comprehensive opinions and court orders resolving a variety of
issues involving the Bankruptcy Code, procedural rules, jurisdictional statutes, state laws, and commercial transactions
• Conference daily with Judge Isgur to discuss matters set for hearing Metro-Goldwyn-Mayer Studios Inc., Los Angeles, California TV Business Affairs Law Clerk, Summer2007 • Observed negotiations with and drafted various contracts for directors, writers, producers, and talent on
dozens of direct to video projects • Managed all project developments and coordinated with outside counsel to take over department Law Offices of Melanie A. Calvert, Altadena, California Employment and Labor Law Clerk, Summer 2007 • Part of a three-person litigation team opposing a motion for summary judgment filed in an employment
retaliation state court case against a public school district • Reviewed all depositions and exhibits to set forth more than 400 disputes to material facts Western Center on Law and Poverty, Los Angeles, California Litigation Law Clerk, Spring 2007 • Authored strategy memoranda on public benefits law, including how the Americans with Disability Act
could be used to challenge a California foster care program eligibility requirement • Participated in the Center’s bi-weekly litigation strategy meetings Asian Pacific American Dispute Resolution Center, Los Angeles, California Conflict Resolution Specialist, Summer 2006 • Used community-based techniques to mediate tenant-landlord and consumer-merchant disputes
EDUCATION Loyola Law School, Los Angeles, California Juris Doctor, May 2008 Distinctions: Dean’s Scholar, Research Assistant Swarthmore College, Swarthmore, Pennsylvania Bachelor of Arts, June 2003 Majors: Political Science and Economics Distinctions: Intercultural Center Award for Distinction in Leadership and Service National Taiwan University, Taipei, Taiwan Advanced training in spoken and written Mandarin-Chinese, Summer 2000 OTHER Professional Affiliations
• The State Bar of California, Member, Dec. 2008 - present • The Moller-Foltz Bankruptcy American Inn of Court, Member, Sept. 2008 - present
Public Policy and Community Work
• Coalition Los Angeles, Board Member, 2005 - 2008 • Public Counsel, Child Care Law Advocate, 2004 • Los Angeles Mayor’s Office, Policy Analyst Intern, 2003 – 2004 • Americans for Democracy, Assistant Campaign Manager, 2003
Interests • Films, cooking, food and wine, world travel
Not-So-Secret Insights for Success in the Eastern District Chapter 14
i
TABLE OF CONTENTS
#1 READ THE LOCAL RULES ................................................................................................................................. 1
#2 READ THE APPENDICES TO THE LOCAL RULES ......................................................................................... 1
#3 BE POLITE AND GRACIOUS TO COURT STAFF ........................................................................................... 1
#4 VIEW AN INVITATION TO SUBMIT A BRIEF AS AN ORDER ..................................................................... 1
#5 DON’T REPEAT THE SAME MISTAKES........................................................................................................... 2
#6 THE LAW CLERK CANNOT GIVE LEGAL ADVICE....................................................................................... 2
#7 READ THE JUDGE’S PREVIOUS ON-POINT OPINIONS ................................................................................ 2
#8 PRECEDENTIAL AUTHORITY V. PERSUASIVE AUTHORITY..................................................................... 2
#9 SUBMIT PROPOSED FINDINGS AND CONCLUSIONS .................................................................................. 2
#10 BE PREPARED WHEN YOU APPEAR IN COURT............................................................................................ 2
CONCLUSION............................................................................................................................................................... 2
APPENDIX:
Some Useful Tips for Practicing in the U.S. Bankruptcy Courts for the Southern District of Texas ............................ 5
Not-So-Secret Insights for Success in the Eastern District Chapter 14
1
NOT-SO-SECRET INSIGHTS These tips are called not-so-secret insights because nothing in this article should be new to you. To remain fresh and to maintain the court’s confidence in our ability and practice, we all need a little refresher course on the Dos & Don’ts of practicing in bankruptcy court. These ten not-so-secret insights are some of the more important keys to success in the Eastern District. #1 Read the Local Rules The most important thing to remember is to read the local rules. This rule applies in every district and should not be taken lightly. Too often, lawyers will appear in court or file documents with no knowledge of the specific local rules of the district, and every district is different. The local rules are keys to success in that district. Failure to comply with the local rules can result in the attorney looking like he or she is ill-prepared or lazy, the judge’s lack of confidence in that attorney, or, more often, dismissal or denial for failure to comply with the local rules. #2 Read the Appendices to the Local Rules The Appendices to the Local Rules contain even more tips for ensuring success. For example, Appendix 5005 is entitled “Administrative Procedures for the Filing, Signing, and Verifying of Documents by Electronic Means in Texas Bankruptcy Courts.” Although Appendix 5005 applies in all districts in Texas, pages 11 and 12 contain a list of the pleadings that each district requires the filing attorney to submit a paper copy of to the court. For example, the Eastern District requires paper copies of: • Chapter 9 and Chapter 11 Plans of
Reorganization. • Disclosure Statements; • Motions for Summary Judgment; • Applications for Compensation and/or
Reimbursement of Expenses when the fee exhibit exceeds 25 pages; and
• Motions to Dismiss pursuant to Fed. R. Bankr. P. 7012 if more than 25 pages.
On the contrary, the Southern District requires paper copies of: • Chapter 9 and Chapter 11 Plans of
Reorganization. • Disclosure Statements; • Any motion or application filed under Fed. R.
Bankr. P. 2014, 7012, 7056, 7065, 9023 or 9024; • Trustee’s Final Report and Account (in all
chapters); and
• Any documents containing affidavits or verified statements.
In addition to the local rules, know the specific’s judge’s personal preferences and use the forms the court has taken the time to prepare. Failure to comply with local rules, procedures and forms not only makes you look bad and denigrates the confidence the court has in your ability to responsibly represent your client’s interests, but it can also result in negative consequences such as dismissal, denial, or, in extreme cases of repeated failures of the same local rule, sanctions. #3 Be Polite and Gracious to Court Staff Frequently, court staff in the Eastern District will call the filing attorney to notify him or her of a deficiency in a filed document. Please understand that this is a courtesy to you and is not required. Do not respond with, “But in the Northern District….” Responses like that put the court staff on notice that you are ungrateful for the money- and time-saving tip and will result in you never receiving a call like that again. As you are aware, one simple misstep, such as forgetting to include the trustee or the creditors who requested notice on the certificate of service in a Motion for Relief From Stay, costs you and your client added time and money to correct, re-notice and re-file the motion. So if someone from the court gives you a courtesy call telling you that if you file a supplemental certificate of service you may be able to save your motion from automatic dismissal for failure to comply with Loc. R. Bankr. Pro. 9013, be grateful and thank the court staff for saving you and your client time and money. #4 View an Invitation to Submit a Brief as an Order Many times, especially when the case is fact intensive or has many contested issues, the judge will invite the attorneys to submit pre- or post-trial briefs. You should view this invitation not only as a chance to more fully develop your side of the argument and to give the judge a clearer understanding of the case law for your client, but also as a formal request from the judge for a more definitive statement of the facts and law. Too often, attorneys fail to take advantage of briefing opportunities, leaving the judge and the law clerk to wade through the mountain of exhibits, pre-trial filings and hearing/trial testimony to piece together the facts of the case, the attorneys’ arguments and the pertinent law. You should see your job as not only representing your client’s interests, but also as making the facts, arguments, and authorities more clear for the judge, who will ultimately decide the case. Attorneys often complain that judges take too long to
Not-So-Secret Insights for Success in the Eastern District Chapter 14
2
deliver opinions, but this rarely happens when the attorneys submitted well-thought-out findings and conclusions and pre- or post-trial briefs. #5 Don’t Repeat the Same Mistakes Many times, the court will receive pleadings and proposed orders that, for the most part, get the point across, but patently fail to include necessary language, include inappropriate findings or over-reaching relief, or even fail to include the correct case number or debtor’s name. When the court grants the motion and enters a corrected or markedly different order than the one submitted (or denies the motion on the grounds that the proposed order fails to comply with a local form), the attorney should take notice of the changes and either implement the changes himself or direct his staff to implement the changes. What tends to occur, however, is that the same attorney repeatedly submits the exact same inappropriate proposed order in every one of her cases, which inevitably irritates the judge to such an extent that he or she automatically denies the underlying motion and directs the law clerk to contact that attorney and chew her out. #6 The Law Clerk Cannot Give Legal Advice Law clerks cannot tell you how to proceed, what to file, how to file it, or when to file it. They cannot tell you what elements you must include, who you must notice, or what the expected outcome will be. They cannot tell you if your fee application will be approved or for how much. They cannot tell you when the decision will be released or in which direction the opinion is heading. If, however, you have read the local rules and cannot find an answer or you do not understand the rule, you can call the law clerk. He or she will likely take down your question, comb through the local rules, and, if he or she cannot locate the answer or decipher the rule, turn to the judge. Only in those circumstances, when the judge has authorized the law clerk to do so, can the law clerk legally give guidance on how to proceed. #7 Read the Judge’s Previous On-Point Opinions The Eastern District website, located at www.txeb.uscourts.gov, contains a link to Judge Parker’s and Judge Rhoades’s opinions both published and unpublished organized by chapter and topic. Before submitting a brief or arguing your case in court, read the judge’s on-point opinions. It’s likely the judge has already ruled on your issue, and if so, it could save you valuable time and your client thousands of dollars. If the opinion is contrary to your side, mentioning it will score you points for candor, credibility and professionalism with the judge. Shirking from the opinion does nothing for your case,
because I assure you the law clerk has reminded the judge of his or her previous ruling. #8 Precedential Authority v. Persuasive Authority Bankruptcy courts in Texas are bound by the Fifth Circuit and U.S. Supreme Court. If you are trying to convince the court with decisions from other circuits, be sure to address or at least mention any significant criticism that case received, especially from the Fifth Circuit. Again, I want to assure you that the law clerks in the Eastern District have already key cited or shepardized the case and alerted the judge to the negative criticism. As much as the court respects advocacy, it admires and remembers candor and credibility much more. #9 Submit Proposed Findings and Conclusions The judge will often allow you to submit proposed findings and conclusions to the court. If you choose to do so, make sure you submit them on a cd or flash drive and in a manipulateable format, i.e. Microsoft Word or WordPerfect. Also, think about them from the court’s perspective and objectively include all of the pertinent facts, both positive and negative, and cover all of the necessary elements so they are usable to the court. #10 Be Prepared When You Appear In Court Whether you are appearing on behalf of yourself, your client, an associate, or even as local counsel, be prepared to represent your client to the fullest extent. It is unacceptable and irritates the court when an attorney appears and either knows nothing about the details of the case or does not know why he or she is appearing before the court. If you are local counsel, be sure to obtain the underlying pleadings and require the referring counsel to send you a factual and procedural synopsis of the case to get you up to speed. Additionally, if you are representing a lender, be sure you not only have the entire financial history of the debtor, but that you also have the authority to make decisions or at least to agree to an extension or a continuation. Simply appearing on behalf of your client is not enough; you must be able to adequately represent your client and to argue the facts and the law to the court. CONCLUSION The commonality in most, if not all, of these tips is that your credibility and regard for judicial efficiency is of utmost importance. To ensure that you remain in high regard with the court, be a conscientious practitioner who is knowledgeable about each court’s preferences and who considers the court’s view of every pleading, hearing and trial. Remember that bankruptcy is a tight niche practice, and if you
Not-So-Secret Insights for Success in the Eastern District Chapter 14
3
continue practicing bankruptcy, you will certainly appear before the same judge or judges time and time again.
SO
ME
USE
FUL
TIP
S FO
R P
RA
CT
ICIN
G IN
TH
E U
.S. B
AN
KR
UPT
CY
CO
UR
TS
FOR
TH
E S
OU
TH
ER
N D
IST
RIC
T O
F T
EX
AS
Pr
epar
ed b
y C
athy
Ta,
Law
Cle
rk to
the
Hon
orab
le M
arvi
n Is
gur,
Chi
ef J
udge
of t
he U
.S. B
ankr
uptc
y C
ourt
for t
he S
outh
ern
Dis
tric
t of T
exas
A
ll in
form
atio
n is
as o
f Oct
ober
2, 2
009.
Ple
ase
refe
r to
the
Judg
es’ w
ebpa
ges f
or th
e m
ost u
p-to
-dat
e in
form
atio
n. T
hank
you
.
Judg
e A
Req
uest
for
an E
mer
genc
y H
eari
ng1
Tel
epho
nic
App
eara
nces
Jeff
Boh
m
By
sepa
rate
mot
ion.
• In
non
-Com
plex
Cha
pter
11
case
s: f
ile a
mot
ion
seek
ing
leav
e to
app
ear b
y te
leph
one.
•
In C
ompl
ex C
hapt
er 1
1 ca
ses:
cal
l the
Cas
e M
anag
er to
mak
e ar
rang
emen
ts.
• D
ial i
n 10
min
utes
prio
r to
the
hear
ing.
2 No
dial
ing
in fr
om a
cel
l pho
ne.
• N
o ev
iden
ce.
Als
o, th
e C
ourt
rese
rves
the
right
to d
isco
nnec
t the
pho
ne if
too
muc
h no
ise
is m
ade
on th
e ph
one.
Kar
en K
. B
row
n B
y se
para
te m
otio
n.
• In
non
-Com
plex
Cha
pter
11
case
s:
requ
est b
y e-
mai
l or
tele
phon
e, a
nd m
ust b
e ap
prov
ed in
adv
ance
. C
all t
he
Cas
e m
anag
er to
mak
e ar
rang
emen
ts.
• In
Com
plex
Cha
pter
11
case
s:
allo
wed
with
or
with
out a
dvan
ce n
otic
e to
the
Cou
rt th
roug
h th
e C
ourt’
s “M
eet-
Me-
Line
.”3 T
he li
ne is
cal
led
by th
e C
ourt
for e
very
Com
plex
Cha
pter
11
case
hea
ring.
Mar
vin
Isgu
r B
y se
para
te m
otio
n, a
nd n
otify
the
Cas
e M
anag
er.
• A
llow
ed w
ithou
t any
prio
r per
mis
sion
or n
otic
e to
the
Cou
rt. P
rohi
bite
d in
Cha
pter
13
pane
l hea
rings
. •
Dia
l in
5 m
inut
es p
rior t
o th
e he
arin
g.4 N
o di
alin
g in
from
a c
ell p
hone
. •
No
evid
ence
, exc
ept t
he C
ourt
may
allo
w w
itnes
ses t
o be
exa
min
ed v
ia te
leph
one
for g
ood
caus
e, i.
e. e
mer
genc
ies.
Letic
ia Z
. Pa
ul
By
sepa
rate
mot
ion,
and
not
ify t
he C
ase
Man
ager
.
• In
non
-Com
plex
Cha
pter
11
case
s: f
ile a
mot
ion
seek
ing
leav
e to
app
ear b
y te
leph
one.
•
In C
ompl
ex C
hapt
er 1
1 ca
ses:
cal
l the
Cas
e M
anag
er to
mak
e ar
rang
emen
ts.5
• N
o ev
iden
ce.
Ric
hard
S.
Schm
idt
By
sepa
rate
m
otio
n,
but
call
the
Cas
e M
anag
er
befo
re
filin
g to
sc
hedu
le
a pr
opos
ed h
earin
g da
te a
nd ti
me.
• A
llow
ed o
nly
on n
on-d
ocke
t cal
l day
s (w
hen
Judg
e Sc
hmid
t is N
OT
hear
ing
McA
llen
or B
row
nsvi
lle d
ocke
ts).
•
Cal
l the
Cas
e M
anag
er 2
day
s in
adva
nce
to m
ake
arra
ngem
ents
.
Wes
ley
W.
Stee
n
Con
tact
the
Cas
e M
anag
er i
f th
e m
atte
r re
quire
s th
e C
ourt’
s at
tent
ion
with
in o
ne
busi
ness
da
y.
O
ther
wis
e,
emer
genc
y m
otio
ns sh
ould
be
avoi
ded.
• M
ust b
e re
ques
ted
at le
ast 2
bus
ines
s da
ys b
efor
e th
e he
arin
g an
d fo
r goo
d ca
use,
i.e.
out
of t
own
coun
sel.
E-m
ail
the
Cou
rtroo
m D
eput
y, B
erdi
ne C
arte
r at c
mA
580d
@tx
s.usc
ourts
.gov
for p
erm
issi
on.6
• If
the
em
erge
ncy
hear
ing
is s
et w
ith l
ess
than
2 d
ays’
not
ice,
the
e-m
ail
mus
t be
sen
t as
soo
n as
not
ice
of t
he
hear
ing
is re
ceiv
ed.
•
Dia
l in
5 m
inut
es p
rior t
o th
e he
arin
g th
roug
h th
e C
ourt’
s “M
eet-M
e-Li
ne.”
7 •
No
evid
ence
.
1.
1 Loc
al R
ule
9013
(i):
Emer
genc
y m
otio
ns m
ay b
e se
lf-ca
lend
ared
thro
ugh
the
judg
e’s
web
page
or m
ust b
e re
ques
ted
by a
sep
arat
e m
otio
n. T
he s
epar
ate
mot
ion
mus
t (1)
incl
ude
a de
taile
d st
atem
ent
why
an
emer
genc
y ex
ists
and
the
date
by
whi
ch th
e re
lief
is n
eede
d to
avo
id th
e co
nseq
uenc
es o
f th
e em
erge
ncy,
and
(2)
be
certi
fied
for
accu
racy
by
the
party
see
king
em
erge
ncy
relie
f or
by
its
coun
sel.
2 The
num
ber f
or Ju
dge
Boh
m’s
tele
phon
ic a
ppea
ranc
e lin
e is
(713
) 250
-557
7.
3 The
num
ber f
or Ju
dge
Bro
wn’
s “M
eet-M
e-Li
ne”
is (7
13) 2
50-5
622.
4 T
here
are
2 o
ptio
ns fo
r dia
ling
into
Jud
ge Is
gur’
s C
ourt:
(1)
Cal
l the
Cou
rt’s
conf
eren
ce s
ervi
ce n
umbe
r at (
201)
793
-902
2; th
e co
nfer
ence
room
no.
is 1
0433
22#;
or (
2) C
all t
he C
ourt
from
you
r co
mpu
ter u
sing
Sky
pe.
Dia
l +99
0082
7041
0433
22.
Plea
se re
fer t
o Ju
dge
Isgu
r’s C
ourtr
oom
Pro
cedu
res,
post
ed o
n hi
s web
page
, for
mor
e de
taile
d in
stru
ctio
ns.
5 Initi
al o
rder
s may
dire
ctly
allo
w fo
r tel
epho
nic
appe
aran
ces i
f arr
ange
d in
adv
ance
. 6 T
he e
-mai
l mus
t inc
lude
: (1
) Cas
e na
me
and
case
num
ber;
(2) D
ate
and
time
of h
earin
g; (3
) Nam
e of
per
son
who
will
app
ear b
y te
leph
one
– if
the
pers
on is
an
atto
rney
, ide
ntify
the
clie
nt; i
f the
pe
rson
is n
ot a
n at
torn
ey, s
tate
the
pers
on’s
rela
tions
hip
to th
e ca
se; a
nd (4
) Doc
ket n
umbe
r(s)
of i
ssue
(s) o
n w
hich
the
pers
on w
ants
to b
e he
ard.
7 T
he n
umbe
r for
Jud
ge S
teen
’s “
Mee
t-Me-
Line
” is
(713
) 250
-524
6.
Whe
n yo
u di
al th
is n
umbe
r, it
will
con
tinue
ring
ing
until
at l
east
two
parti
es h
ave
dial
ed th
e nu
mbe
r. A
llow
the
tele
phon
e to
rin
g. T
he ri
ngin
g w
ill s
top
whe
n th
e se
cond
par
ty d
ials
the
num
ber a
nd is
con
nect
ed.
Add
ition
al p
artie
s w
ill b
e co
nnec
ted
imm
edia
tely
. Pl
ease
refe
r to
Judg
e St
een’
s C
ourtr
oom
Pro
cedu
res,
post
ed
on h
is w
ebpa
ge, f
or m
ore
deta
iled
inst
ruct
ions
.
Not-So-Secret Insights for Success in the Eastern District Chapter 14
5
SO
ME
USE
FUL
TIP
S, C
ON
TIN
UE
D
1.
8 Loc
al R
ule
9013
(h):
Each
mot
ion,
app
licat
ion,
obj
ectio
n, a
nd re
spon
se fi
led
with
the
cour
t mus
t be
acco
mpa
nied
by
a pr
opos
ed o
rder
. 9 Ju
dge
Boh
m re
quire
s tha
t a re
ason
or r
easo
ns b
e st
ated
in th
e N
otic
e as
to w
hy th
e pl
eadi
ng is
bei
ng w
ithdr
awn.
10
Con
tact
the
Cas
e M
anag
er re
gard
ing
your
Not
ice
of W
ithdr
awal
and
be
sure
to li
nk th
e N
otic
e pr
oper
ly to
the
mot
ion(
s) b
eing
with
draw
n.
Judg
e C
ase
Man
ager
N
ame
Pref
erre
d C
onta
ct M
etho
d(s)
Fi
le a
n or
der
with
eve
ry
mot
ion8
To
chec
k on
the
stat
us
of y
our
orde
r, w
ait _
_ da
ys a
fter
you
r m
otio
n is
file
d:
To
with
draw
a p
lead
ing,
you
mus
t file
:
Jeff
Boh
m
Rob
in S
tenn
is
E-m
ail:
cm
A67
9@tx
s.usc
ourts
.gov
Y
es
23 d
ays
A N
otic
e of
With
draw
al9
Kar
en K
. Bro
wn
Mau
reen
Bry
an
Phon
e: (
713)
250
-544
5 E-
mai
l: c
mA
487@
txs.u
scou
rts.g
ov
Yes
45
day
s (1
) A M
otio
n an
d an
Ord
er to
With
draw
OR
(2
) A N
otic
e of
With
draw
al
Mar
vin
Isgu
r A
nita
Dol
ezel
E-
mai
l: c
mA
671@
txs.u
scou
rts.g
ov
Yes
33
day
s A
Not
ice
of W
ithdr
awal
Letic
ia Z
. Pau
l M
aria
O.
Rod
rigue
z Ph
one:
(71
3) 2
50-5
410
Yes
35
day
s (1
) A M
otio
n an
d an
Ord
er to
With
draw
OR
(2
) Not
ice
of W
ithdr
awal
Ric
hard
S. S
chm
idt
Letty
Gar
za
Phon
e: (
361)
888
-348
4 E-
mai
l: c
mA
417@
txs.u
scou
rts.g
ov
Yes
23
day
s A
Not
ice
of W
ithdr
awal
10
Wes
ley
W. S
teen
Je
an K
ell
Phon
e: (
713)
250
-577
9 Y
es
35 d
ays
A N
otic
e of
With
draw
al
Not-So-Secret Insights for Success in the Eastern District Chapter 14
6