N0. 01-15-00589-CV

 

IN THE COURT OF APPEALS

FOR THE FIRST DISTRICT

OF TEXAS AT HOUSTON 

 

IN THE INTEREST OF

T.J.C.,II, CHILD

 

J.J.K., APPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE

 

 

ON APPEAL FROM 

THE 313TH DISTRICT COURT OF

HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 2014-01481J-A 

 

 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, J.J.K., respondent mother, and 

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ACCEPTED

01-15-00589-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

12/28/2015 7:34:34 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/28/2015 7:34:34 PM CHRISTOPHER A. PRINE Clerk
hereby files this Motion for Withdrawal of Counsel. Donald M. Crane 

requests the Court grant him leave to withdraw as Attorney ad litem on appeal 

for Appellant J.J.K., 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 November 

18, 2015, to Appellant enclosing a copy of the Court’s

Memorandum Opinion dated November 5, 2015, (“Memorandum

Opinion“) by U.S. First Class Mail to Appellant’s last known

address: 

4146 Peal Valley Court

Fresno, Texas 77489

(281) 795-4821.

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 her own

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

but that such 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

filing deadline of December 20, 2015, and that should she

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

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

6. 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 assistance.

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7. Finally, Appellate counsel advised Appellant of her right to

object to this motion for withdrawal of counsel, enclosing then 

forwarding a copy of said motion December 28, 2015 to 

Appellant’s last known address: 

4146 Peal Valley Court

Fresno, Texas 77489

(281) 795-4821.

WHEREFORE, PREMISES CONSIDERED, Donald M. Crane prays 

that the Court enter an order discharging him as Appellate Counsel for J.J.K.

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

APPELLANT J.J.K.

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CERTIFICATE OF CONFERENCE

This motion is unopposed.

/s/ Donald M. Crane 

Donald M. Crane

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CERTIFICATE OF SERVICE

I hereby certify that on this 28th day of December, 2015, a true 

and correct copy of the foregoing Motion for Withdrawal of Counsel 

was served in accordance with the TRAP.

1. Sandra D. Hachem

Senior Assistant County Attorney

1019 Congress Avenue, 16th Floor

Houston, Texas 77002-1700

(713) 437-4700 fax

2. Susan Ryan Solis

2800 East Broadway, Suite c-518

Pearland, Texas 77581

(281) 317-9908 fax

/s/ Donald M. Crane

Donald M. Crane

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