N0. 01

- 15

- 00 589

- CV

IN THE COURT OF APPEALS

FOR THE F IRST D ISTRICT

OF TEXAS AT HOUSTON

IN THE INTEREST OF

T.J.C.,II , CHILD

J.J.K. , 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 14- 01481 J-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

Page 1 of 5 ACCEPTED

01-15-00589-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

12/28/2015 7:34:34 PM

CHRISTOPHER PRINE

CLERKhereby files this Motion for Withdrawal of Counsel. Donald M. Crane

requests the Court grant him leave to withdraw as Atto rney 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

1 8

, 2015, to Appellant enclosing a copy of the C ourt’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 77 489

( 281) 7 95

- 4821

.

2

. Appel late 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

f

iling d eadline of December 20 , 2015, and that should she

pursue a petition for r eview 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

.

Page 2 of 57

. Finally, Appellate counsel advised Appellant of her right to

object to this motion for withdrawal of counsel, enclosing then

for warding a copy of said motion December 28, 2015 to

Appellant’s last known address:

4146 Peal Valley Court

Fresno, Texas 77489

( 281 ) 7 95

- 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

A

PPELLANT J.J.K.

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 8

th 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, 1 6 th 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

Page 5 of 5