N0. 01

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- CV

IN THE COURT OF APPEALS

FOR THE F IRST D ISTRICT

OF TEXAS AT HOUSTON

IN THE INTEREST OF

S. R.

- M.C., C HILD

R.A.C., SR., AKA R.C., A PPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE

ON APPEAL FROM

THE 31 3 TH DISTRICT COURT OF

HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 20 10- 08247 J

UNOPPOSED MOTION FOR WITHDRAWAL OF COUNSEL

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW DONALD M. CRANE (“appellate counsel”), appointed

attorney ad litem on appeal for Appellant, R.A.C., Sr., aka R.C. , respondent

Page 1 of 5 ACCEPTED

01-15-00556-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

12/28/2015 8:18:49 PM

CHRISTOPHER PRINE

CLERKfather , and hereby files this Unopposed Motion for Withdrawal of Counsel.

Donald M. Crane requests the Court grant him leave to withdraw as Attorney

ad litem on appeal for Appellant R.A.C., Sr., aka R.C., in accordance with

Texas Rules of Appellate Procedure (“TRAP”) Tex. R. App. P. 6.5, and in

support would show as follows:

1

. Appellate counsel forwarded correspondence dated December 2 9

, 2015, to Appellant enclosing a copy of the C ourt’s Memorandum

Opinion dated November 17

, 2015, (“ Memorandum Opinion“ )

by U.S. First Class Mail and Certif ied Mail, Return Receipt

Requested #701 4 2120 0003 3959 1292 to Appellant’s last

known address:

10091 Stonybrook Circle, Apt. A

Indianapolis, Indiana 46229

( 317 ) 912

- 5762

.

2

. Appellate counsel advised of his duty to re

- evaluate the appeal to

determine the merit of further appellate action and advised that

such is frivolous. Tex. R. App. P. 62

.

3

. Appellate counsel further explained that Appellant on h is own

may pursue a petition for review in the Supreme Court of Texas,

but that suc h is frivolous

.

4

. Appellate counsel further explained that Appellant should retain

private counsel as to the merits of pursuing a petition for review

in the Supreme Court of Texas

.

5

. Appellate counsel further explained that Appellant has a current

f

iling d eadline of January 4 , 2016

, and that should he

pursue a petition for r eview in the Supreme Court of Texas, he

should first consult Tex. R. App. P. 53

.

Page 2 of 56

. Appellate counsel further explained that Appellant may

Contact the Supreme Court of Texas, P.O. Box 12248,

Austin, Texas 78711, (512) 463

- 1312, for further information

.

7

. Finally, Appellate counsel advised Appellant of h is right to

object to this motion for withdrawal of counsel, enclosing then

for warding a copy of said motion December 2 9 , 2015 by U.S.

First Class Mail and Certified Mail, Return Receipt Requested

#701 4 2120 0003 3959 1292 to Appellant’s last known address:

10091 Stonybrook Circle, Apt. A

Indianapolis, Indiana 46229

( 317) 912

- 5762.

WHEREFORE, PREMISES CONSIDERED, Donald M. Crane prays

that the Court enter an order discharging him as Appellate Counsel for R.A.C.,

Sr. aka R.C.

Respectfully submitted,

/s/ Donald M. Crane

Donald M. Crane

810 South Mason Road, Suite

350

Katy, Texas 77450

Telephone (281) 392

- 6611

Facsimile (281) 392

- 5383

State Bar No. 05005900

donmcrane@gmail.com

ATTORNEY AD LITEM ON

APPEAL FOR

A

PPELLANT R.A.C., SR.,

aka R.C.

Page 3 of 5CERTIFICATE OF CONFERENCE

This motion is unopposed

.

/s/ Donald M. Crane

Donald M. Crane

Page 4 of 5CERTIFICATE OF SERVICE

I hereby certify that on this 2 9

th day of December , 2015, a true

and correct copy of the foregoing Unopposed Motion for Withdrawal of

Counsel was served in accordance with the TRAP

.

1. Sandra D. Hachem

Senior Assistant County Attorney

1019 Congress Avenue, 1 6 th Floor

Houston, Texas 77002

- 1700

(713) 437

- 4700 fax

2. Sylvia Yvonne Escobedo

917 Franklin, Suite 100

Houston, Texas 77002

- 1930

(713) 655

- 0200 fax

/s/ Donald M. Crane

Donald M. Crane

Page 5 of 5