N0. 01

- 15

- 00 5 71

- CV

IN THE COURT OF APPEALS

FOR THE F IRST D ISTRICT

OF TEXAS AT HOUSTON

IN THE INTEREST OF

A.G. AND F.G., CHILDREN

S.F., 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 13- 06904 J

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, S.F. , respondent mother, and hereby

Page 1 of 5 ACCEPTED

01-15-00571-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

12/28/2015 7:39:02 PM

CHRISTOPHER PRINE

CLERKfiles this Motion for Withdrawal of Counsel. Donald M. Crane requests the

Court grant him leave to withdraw as Attorn ey ad litem on appeal for

Appellant S.F. , 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 28,

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

Opinion dated December 3, 2015, (“ Memorandum Opinion“ ) by

U.S. First Class Mail and Certified Mail, Return Receipt

Requested #7011 1150 0001 3843 9600 to Appellant’s last

known address:

832 Wh ite Boulevard, #104

McComb, MS 39648

( 601 ) 341

- 4813

.

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 coun sel 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 January 17, 2016

, 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 assis tance

.

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 by U.S.

First Class Mail and Certified Mail, Return Receipt R equested

#7011 1150 0001 3843 9600 to Appellant’s last known address:

832 White Boulevard, #104

McComb, MS 39648

( 601) 341

- 4813.

WHEREFORE, PREMISES CONSIDERED, Donald M. Crane prays

that the Court enter an order discharging him as Appellate Cou nsel for S.F.

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 S.F.

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. John R. Millard

1 Sugar Creek Center Boulevard, Suite 925

Sugar Land, Texas 77478

/s/ Donald M. Crane

Donald M. Crane

Page 5 of 5