Carolyn Barnes v. State

Opinion

ACCEPTED

03-12-00631-CV

4700848

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/30/2015 5:09:56 PM

JEFFREY D. KYLE

CLERK

THIRD COURT OF APPEALS FILED IN FOR THE STATE OF TEXAS 3rd COURT OF APPEALS AUSTIN, TEXAS

3/30/2015 5:09:56 PM

STATE OF TEXAS JEFFREY D. KYLE Clerk

VS.

No. 03-12-00631-CV

CAROLYN BARNES

MOTION TO WITHDRAW AS COUNSEL Mr. Shannon Hooks, attorney of record in the above case, hereby moves this court to allow counsel to withdraw from representing the appellant for the following reasons:

Appellant has filed a civil lawsuit in Travis County, Texas, (Cause no.

D-1-GN-15-000877) naming counsel as one of the defendants. Counsel is required to respond to the civil petition within 20 days.

Counsel strongly believes that defending himself in the civil lawsuit while continuing to represent the appellant in this case will result in prejudice to both parties in their respective cases. Counsel therefore requests that this court allow present counsel to withdraw as attorney in this case, so that new counsel can be appointed to represent the appellant regarding all future rights of appeal.

Counsel hereby certifies that he has sent by certified mail and first class mail to appellant Carolyn Barnes, 419 Indian Trail, Leander, Texas 78641, her last known address, a copy of this Motion along with a letter informing her of her right to object to the Motion.

Respectfully submitted,

/s/Shannon Hooks

Shannon C. Hooks #24045001 Attorney for Appellant

6910 Hart Lane #510

Austin, Texas 78731

Certification of Conference with Opposing Counsel Counsel hereby certifies that today, March 30, 2015, he has conferred with attorney John Prezas, of the Williamson County District Attorney‘s Office regarding this Motion. Mr. Prezas has informed counsel that he has no objection to counsel’s Motion to Withdraw.

CERTIFICATE OF SERVICE

I, Shannon Hooks, hereby certify that a true and exact copy of the foregoing has been sent via U.S. Mail Service to the Williamson County Attorney’s office on this 30th day of March 2015.

/s/Shannon Hooks

Shannon Hooks