Beruflich Dokumente
Kultur Dokumente
EXHIBITC
Gretchen Sween
Wednesday, October21, 2015 5:50 PM
'Seth Kretzer'
James Volberding
RE: RAPHAEL HOLIDAY
Thank you. I read your email before I sent mine. We will file the motion and indicate your
position. See attached. Sincerely, Wes Volberding
Web: www.jamesvolberding.com
Web: www.easttexasdebtcollection.com
Mr. Volberding,
Our emails may have passed, but as I just explained to Seth, I have not been retained (nor am I
qualified under the statute) to serve as 3599 counsel. Therefore, the motion needs seek to
withdraw and appointment of qualified substitute counsel (unnamed)-who can then seek a stay.
If you are interested in filing a motion of that sort, I might not likely oppose it but I think it is the
State with whom you will have to confer, since I am simply the attorney who noticed the appeal
on Mr. Holiday's behalf. I am happy to review a revised motion and see if you can represent that
we have conferred and represent my stance on the motion.
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Best,
Gretchen Sween
Ms. Sween - Good afternoon. Please find attached our proposed motion to allow you to
substitute as counsel for Raphael. Please tell me whether you oppose or agree to the motion.
Sincerely, Wes Volberding
Web: www.jamesvolberding.com
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