houston #3919721 v1 motion for ad litem

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NO. ___________ GUARDIANSHIP OF § IN PROBATE COURT NO. ___ § PATRICIA ANN THOMAS, § § OF § AN INCAPACITATED PERSON § HARRIS COUNTY, TEXAS MOTION FOR APPOINTMENT OF ATTORNEY AD LITEM STELLA LOUISE THOMAS BRADIX ("Movant") files this Motion for Appointment of Attorney Ad Litem and respectfully shows the Court the following: 1. There is currently pending in the above-referenced proceeding an Application for Appointment of Guardian of the Person and Estate of PATRICIA ANN THOMAS (“Proposed Ward”). Movant requests that this Court appoint an attorney ad litem to represent the interests of Proposed Ward in this proceeding under Section 646 of the Texas Probate Code. WHEREFORE, PREMISES CONSIDERED, Movant request that this Court (i) appoint an attorney ad litem for Proposed Ward to represent his interests in this proceeding and (ii) grant such other and further relief to which Applicant may show herself justly entitled. Respectfully submitted,

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HOUSTON #3919721 v1 Motion for Ad Litem

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Page 1: HOUSTON #3919721 v1 Motion for Ad Litem

NO. ___________

GUARDIANSHIP OF §  IN PROBATE COURT NO. ___§ 

PATRICIA ANN THOMAS, § § 

OF

§ AN INCAPACITATED PERSON §  HARRIS COUNTY, TEXAS

MOTION FOR APPOINTMENT OF ATTORNEY AD LITEM

STELLA LOUISE THOMAS BRADIX ("Movant") files this Motion for Appointment of

Attorney Ad Litem and respectfully shows the Court the following:

1. There is currently pending in the above-referenced proceeding an Application for

Appointment of Guardian of the Person and Estate of PATRICIA ANN THOMAS (“Proposed

Ward”). Movant requests that this Court appoint an attorney ad litem to represent the interests of

Proposed Ward in this proceeding under Section 646 of the Texas Probate Code.

WHEREFORE, PREMISES CONSIDERED, Movant request that this Court (i) appoint

an attorney ad litem for Proposed Ward to represent his interests in this proceeding and (ii) grant

such other and further relief to which Applicant may show herself justly entitled.

Respectfully submitted,

BRACEWELL & GIULIANI LLP

By: ________________________John A. YatesState Bar Number: 24056569711 Louisiana, Suite 2300Houston, Texas 77002-2770Telephone: (713) 221-1375Facsimile: (713) 222-3296

ATTORNEYS FOR MOVANT

Page 2: HOUSTON #3919721 v1 Motion for Ad Litem

NO. ___________

GUARDIANSHIP OF §  IN PROBATE COURT NO. ___§ 

PATRICIA ANN THOMAS, § § 

OF

§ AN INCAPACITATED PERSON §  HARRIS COUNTY, TEXAS

ORDER APPOINTING ATTORNEY AD LITEM

On this day came on to be considered the Motion for Appointment of Attorney Ad Litem

(“Motion) filed herein by STELLA LOUISE THOMAS BRADIX to request the appointment of

an attorney ad litem to represent the interests of PATRICIA ANN THOMAS (“Proposed Ward”)

in the above-referenced proceeding. The Court finds that such Motion is well taken and should

be granted. The Court further finds the appointment of an attorney ad litem is in the best interest

of Proposed Ward. It is, therefore,

ORDERED that _________________, an attorney at law licensed to practice in the state

of Texas and before this Court, is hereby appointed as attorney ad litem to represent the interests

of Proposed Ward in the above-referenced proceeding.

SIGNED on this the _____ day of January 2012.

__________________________________________JUDGE PRESIDING

#3919721.1