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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 [email protected] CATHY TA, Houston Law Clerk to Judge Marvin Isgur (713) 250-5372 [email protected] State Bar of Texas 27 th ANNUAL ADVANCED BUSINESS BANKRUPTCY COURSE October 1-2, 2009 Houston CHAPTER 14
Transcript
Page 1: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

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

[email protected]

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

Page 2: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite
Page 3: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

LIZ BOYDSTON

Fulbright & Jaworski, L.L.P. 2200 Ross Avenue, Suite 2800

Dallas, Texas 75201 214-855-7475

[email protected]

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.

Page 4: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite
Page 5: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

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.

Page 6: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite
Page 7: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

ALLEN M. DEBARD6410 BLANCH CIRCLE

DALLAS, TEXAS 75214

214.926.2396

[email protected]

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.

Page 8: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite
Page 9: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

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

Page 10: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite
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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

Page 12: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite
Page 13: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

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

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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

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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.

Page 16: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite
Page 17: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

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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

Page 18: Author & Speaker: LIZ BOYDSTON - TexasBarCLEAuthor & Speaker: LIZ BOYDSTON Former Law Clerk to Chief Bankruptcy Judge Bill Parker Fulbright & Jaworski, LLP 2200 Ross Avenue, Suite

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


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