ACCEPTED 15-24-00095-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 1/23/2025 5:10 AM CHRISTOPHER A. PRINE Court of Appeals Number: 15-24-00095-CV CLERK RECEIVED IN 15th COURT OF APPEALS Trial Court Case Number: D-1-GN-24-002025 AUSTIN, TEXAS 1/23/2025 5:10:05 AM CHRISTOPHER A. PRINE Clerk Edward Rudolph Turnbull, IV v. IN THE COURT OF APPEALS Commission for Lawyer Discipline, Daniela Grosz, Daniel Martinez, Seana FIFTEENTH DISTRICT Willing, John S. Brannon, Amanda Kates, Jenny Hodgkins, and the Board AT AUSTIN, TEXAS of Directors of the State Bar of Texas, Cindy V. Tisdale, Steve Benesh, Laura Gibson, Kennon Lily Wooten, et al.
SECOND AMICI CURIAE BRIEF
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1 TABLE OF CONTENTS TABLE OF AUTHORITIES............................................................................ iii INTEREST OF AMICUS CURIAE............................................................... 4 AMICUS CURIAE CITIZEN’S STATEMENT……………………………… 5 SUMMARY OF ARGUMENT………………………………………..……… 5 ARGUMENT…………………………………………………………………. 5 I. Appellant seeks impartial and with integrity investigation and disclosures and from the part of the incumbent Chief Disciplinary Counsel Seana Beckerman Willing and her staff employees as persons serving as Chief Disciplinary Counsel in the State Bar of Texas and scattered allotted in regional offices of the CDC of SBOT, but the constitutional question is: The incumbent Chief Disciplinary Counsel Seana Beckerman William is one legitimate office holder and allotted at the public office of the Office of the Chief Disciplinary Counsel of the State Bar of Texas in her individual and official capacity and that is allotted in one Statewide Public Corporation and also being one Statewide Administrative Agency of the Judicial Branch Entity of the State Government of the State of Texas as Quasi State Entity, as well as, her staff employees and serving as Chief Disciplinary Counsel in the State Bar of Texas and under the compliance of the Texas Constitution, Article 1, Section XVI for legitimate office holders allotted at the Offices of the Chief Disciplinary Counsel of the State Bar of Texas and with (Statement Officer (Anti-Bribery Statement) form and Sworn Oath of Office Affidavit form signed, notarized publicly and administered by one legitimate officer of the Board of Officers and Directors of the State Bar of Texas to testify the sworn public ceremony of the new office holders allotted in the SBOT..................... 5 CONCLUSION………………………………………………………………… 12 CERTIFICATE OF SERVICE……………………………………………….. 13 ii 2 TABLE OF AUTHORITIES Cases Page(s) Edward Rudolph Turnbull, IV v. Commission for Lawyer Discipline, Daniela Grosz, Daniel Martinez, Seana Willing, John S. Brannon, Amanda Kates, Jenny Hodgkins, and the Board of Directors of the State Bar of Texas, Cindy V. Tisdale, Steve Benesh, Laura Gibson, Kennon Lily Wooten, et al. Civil Case: 15-24-00095-CV –COA 15th District at passim Austin……………………………………………………………………..
Statutes Texas Citizens Participation Act (“TCPA”)……………………………… 9 Texas Civil Practice & Remedies Code Section 66.001(1)(2)(3)(4)(5)…. 6 Texas Public Information Act (“PIA”)…………………………………… 9 Texas Rules Appellate Procedure (TRAP) Texas Rules Appellate Procedure (TRAP) Rule 11 (c)………………….. 5 State Constitution Texas Constitution, Article 1, Section XVI……………………………… 5, 7 Other Authorities Statement Officer (Anti-Bribery Statement) Form 2201………………… passim Sworn Oath Office Affidavit Form 2204………………………………… passim
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3 INTEREST OF AMICUS CURIAE This second Amicus Curiae brief is about the constitutional status of the
current office holders allotted in one statewide public corporation and also being
one statewide administrative agency and lodged in the judicial branch entity of the
State Government of the State of Texas as Quasi State Entity.
Amicus respectfully brings one constitutional matter and of which has been
systematically ignored in Texas and from State Government Employees as Texas
Public Employees, Public Officers and Public Officials allotted in any Texas
Public Offices as Texas Public Servants as Office Holders and including in
statewide public corporations like the State Bar of Texas and that is one Statewide
Administrative Agency too.
In light of the fact that a litany of immunities and other doctrines close the
courthouse doors (both in federal and state courts) on victims who would otherwise
individually seek accountability for such misconduct in the form of compensatory
damages or injunctive relief, at least this Article III Court could question about the
current constitutionality status of the Office Holders and allotted at the Public
Offices in the Administrative Structure of the Statewide Public Corporation and
Statewide Administrative Agency of the State Bar of Texas.
4 AMICUS CURIAE CITIZEN’S STATEMENT
In compliance with the Texas Rules Appellate Procedure (TRAP) Rule 11 (c);
Amicus Curiae Citizen states that he did not receive any fee paid or to be paid for
preparing the second amicus curiae brief.
SUMMARY OF ARGUMENT When the Chief Disciplinary Counsel (“CDC”) and her staff of employees
violate the constitution of Texas, Article 1, Section XVI, justice demands two
things under the Petition for Quo Warranto:
1) Accountability for the offending officers, officials and employees under
the Petition for Quo Warranto and filed by the Attorney General of Texas to
remove of the public offices of the State Bar of Texas, illegitimate Office Holders,
and
2) Vindication for the Citizens in Texas as Public Concern matter.
ARGUMENT I. Appellant seeks impartial and with integrity investigation and disclosures and from the part of the incumbent Chief Disciplinary Counsel Seana Beckerman Willing and her staff employees as persons serving as Chief Disciplinary Counsel in the State Bar of Texas and scattered allotted in regional offices of the CDC of SBOT, but the constitutional question is: The incumbent Chief Disciplinary Counsel Seana Beckerman William is one legitimate office holder and allotted at the public office of the Office of the Chief Disciplinary Counsel of the State Bar of Texas in her individual and 5 official capacity and that is allotted in one Statewide Public Corporation and also being one Statewide Administrative Agency of the Judicial Branch Entity of the State Government of the State of Texas as Quasi State Entity, as well as, her staff employees and serving as Chief Disciplinary Counsel in the State Bar of Texas and under the compliance of the Texas Constitution, Article 1, Section XVI for legitimate office holders allotted at the Offices of the Chief Disciplinary Counsel of the State Bar of Texas and with (Statement Officer (Anti-Bribery Statement) form and Sworn Oath of Office Affidavit form signed, notarized publicly and administered by one legitimate officer of the Board of Officers and Directors of the State Bar of Texas to testify the sworn public ceremony of the new office holders allotted in the SBOT? Illegitimate office holders are liable for summary removal of the public
offices and under the Texas Civil Practice & Remedies Code Section
66.001(1)(2)(3)(4)(5) as an action in the nature of quo warranto and including for
illegitimate statewide public corporation employees and holding illegitimately as
office holders in public offices of the statewide public corporation in the State of
Texas.
The Attorney General of Texas should request to the current Chief
Disciplinary Counsel Seana Beckerman William and her staff employees, copies of
the filing forms for Statement Officer (Anti-Bribery Statement Forms) and Sworn
Oath of Office Affidavit Forms filed before to take office as office holders allotted
at the Offices of the Chief Disciplinary Counsel of the State Bar of Texas as
Statewide Public Corporation and of which should be duly registered with the
Texas Secretary of State in the Corporation Section and with their respective
6 Officers elected by the Members of the Attorneys Texas Trade Association and
called State Bar of Texas as Statewide Public Corporation and Statewide
Administrative Agency in the State of Texas.
The Citizens in Texas have been systematically denied grievance fairness,
impartial and integrity redress and because the State Bar of Texas is one Quasi
State Entity and having a flagrant conflict of interest between the inner circle of the
cronies’ cartel and from the secretive administrative quasi judicial adjudicatory
proceedings dismissed for the so called no “just cause” and not complying with the
statutory provisions required by the state statute “State Bar Act”.
The constitutional question and of which the Appellant has not raised in his
Appellant’s Opening Brief is to know if the current Office Holders of the State Bar
of Texas are holding constitutionally the public offices of the State Bar of Texas as
legitimate Office Holders and in compliance with the Texas Constitution, Article 1,
Section XVI and to hold legitimately public offices in Texas.
Amicus Curiae has requested amicably with the Texas Secretary of State in
2022, 2023, 2024 and in 2025, but the answer has been that the Texas Secretary of
State does not have in the record of the State Department in Texas any such copies
of the filing forms and required by the Texas Constitution and before one office
holder to take a public office as a legitimate Office Holder in one Public Office
with the State Bar of Texas.
7 Amicus Curiae has requested amicably with the Public Affairs Counsel Ms.
Claire Reynolds and allotted at the Office of the Chief Disciplinary Counsel of the
State Bar of Texas at Austin’s Headquarters Office such Statement Officer (Anti
Bribery Statement) Form and the Sworn Oath of Office Affidavit Form signed,
notarized publicly and administered by one legitimate Officer of the Board of
Officer and Directors of the State Bar of Texas and under the custodian of the
Office of the Chief Disciplinary Counsel of the State Bar of Texas or with the
Human Resources Department of the State Bar of Texas or with the Executive
Director’s Office of the State Bar of Texas or with the Office of Open Records for
Public Information Act with the State Bar of Texas and the response from Ms.
Reynolds has been that there is nothing in custodian in any Public Office of the
Administrative Structure of the State Bar of Texas about the filing forms and
required by the Texas Constitution.
It is important to mention that the title job as Chief Disciplinary Counsel
(“CDC”) of the State Bar of Texas is used for any persons that serve as Chief
Disciplinary Counsel in the offices of the Chief Disciplinary Counsel in the State
Bar of Texas Administrative Structure.
It means that the state government employees of the State Bar of Texas and
allotted at the Offices of the Chief Disciplinary Counsel and that work and sign
documents on behalf of the Chief Disciplinary Counsel (“CDC”) in the scattered
offices of the CDC of SBOT and being all classified as State Government
8 Employees or Public Officers or Public Officials as Texas Public Servants; they
are obligated to comply with the constitutional requirement of the Texas
Constitution and to occupy legitimately one public office as one legitimate Office
Holder in the Statewide Public Corporation and also being one Statewide
Administrative Agency in the judicial branch entity of the State Government of the
State of Texas.
Amicus Curiae has requested via the Open Records Department of the State
Bar of Texas via Public Information Act (“PIA”) and also under the state statute
Texas Citizens Participation Act (“TCPA”) and to communicate with the
government and in any kind of the communication and having sent email messages
addressed to Mr. Chris Critter as Chief Legal Counsel of the Executive Committee
of the Board of State Bar of Texas; who is one expert in the Public Information Act
(“PIA”) and from the Open Records Department of the State Bar of Texas and also
having been requested the same request (again) to Ms. Claire Reynolds as Public
Affairs Counsel of the Office of the Chief Disciplinary Counsel of the State Bar of
Texas, but at the present time, the Open Records Department of the State Bar of
Texas and responsible to release public information to Requester, but such request
has been denied for such copies of the Statement Officer (Anti-Bribery Statement)
Form and the Sworn Oath of Office Affidavit Form, as well as, other public
information has been requested about the quorum of the voluntary public members
of the Summary Disposition Panel (“SDP”) of the Grievance Committee District
9 Number 7 of the State Bar of Texas and that is necessary to participate (06) six
voluntary public members and to deliberate their votes about the CDC’s
recommendations for summary dismissals of the grievance complaints supposedly
investigated and submitted in one summary disposition docket for review of the
Summary Disposition Panel (“SDP”) of the grievance committee district of the
State Bar of Texas and for review if the grievance complaint assigned should be
dismissed for “no just cause” or not dismissed and having been found by the
Summary Disposition Panel (“SDP”) “just cause” and to be forwarded to one
Investigatory Administrative Panel of the grievance committee district of the State
Bar of Texas and for further administrative quasi judicial adjudicatory proceeding.
Such request has been done and because one Outsource Private Independent
Forensic Auditor and paid by the Board of Officers and Directors of the State Bar
of Texas has issued one annual report in the year of 2021 about the Chief
Disciplinary Counsel Processes and having reported in his forensic audit report that
there are certain Summary Disposition Panels (“SDPs”) of the grievance
committees of the State Bar of Texas that don’t have enough public members and
to form a quorum for grievance committee meetings and for Summary Disposition
Panels (“SDPs”) and having been labeled by the Attorney Gaines West and from
College Station, Texas in one of his Responses to the Court that such Summary
Disposition Panel (“SDP”) is a sham process.
10 Amicus has verified in the annual audit services report of the year of 2021
that such assertion of the Attorney Gaines West is clearly corroborated with the
outsource private independent forensic auditor’s report and that notably the Board
of Officers and Directors of the State Bar of Texas and from the Executive
Committee of the Board has not discussed such disdain and no compliance with the
Texas Disciplinary Rules Procedure and promulgated by the Supreme Court of
Texas, and in relation the minimum quorum of the voluntary members of the
grievance committee districts and from the Summary Disposition Panels (“SDPs”)
and that it is necessary to participate in the deliberative votes of the CDC’s
meetings about the summary disposition dockets submitted by CDC and to the
Panel and for review of the grievance complaints assigned and supposedly
investigated by one regional investigator assigned in one regional office of the
CDC of SBOT.
Also, according with the Assistant Chief Disciplinary Counsel Luvenia Evett
Sanchez and allotted at Dallas Regional Office of the CDC of SBOT, the Summary
Disposition Panel (“SDP”) of the grievance committee district number 7 of the
State Bar of Texas has never denied at least one single CDC’s recommendation for
summary dismissal for “no “just cause” and submitted from one summary
disposition docket to the Panel and since the date that the Chief Disciplinary
Counsel Seana Beckerman Willing has entered as the new Chief Disciplinary
Counsel of the State Bar of Texas in January 2019, and having been adopted the
11 internal policy “weeded out” for 90% of the grievance complaints submitted and
being summarily dismissed.
CONCLUSION The Court should reverse and hold that Appellant is entitled to one impartial
and integrity investigation and disclosure obligations that he seeks in one impartial
and integrity investigation with transparency and that it is consistent in one
democratic society and that it defends the liberty and the civil rights of the Citizens
and make accountable unelected apparatchiks allotted in State Bar of Texas.
Dated: January 23, 2025
Respectfully submitted,
/s/Adriano Kruel Budri Adriano Kruel Budri Amici Curiae Citizen 5029 County Road 605 Burleson, TX 76028-1177 Email address: abudri64@gmail.com
12 CERTIFICATE OF SERVICE I certify that I served all parties to this appeal through the Court’s electronic
filing system, including Appellant’s and Appellee’s counsel on the 23th day of
January 2025.
/s/Adriano Kruel Budri Adriano Kruel Budri Amici Curiae Citizen 5029 County Road 605 Burleson, TX 76028-1177 Email address: abudri64@gmail.com
13 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Envelope ID: 96502251 Filing Code Description: Other Brief Filing Description: SECOND AMICI CURIAE BRIEF Status as of 1/23/2025 7:19 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Pat Mizell pmizell@velaw.com 1/23/2025 5:10:05 AM SENT
Billy SHart billy.hart@westwebblaw.com 1/23/2025 5:10:05 AM SENT
Jay Rudinger jay.rudinger@westwebblaw.com 1/23/2025 5:10:05 AM SENT
Jadd Masso 24041411 jmasso@clarkhill.com 1/23/2025 5:10:05 AM SENT
Royce Lemoine 24026421 royce.lemoine@texasbar.com 1/23/2025 5:10:05 AM SENT
Richard Huntpalmer 24097857 Richard.Huntpalmer@texasbar.com 1/23/2025 5:10:05 AM SENT
Gaines West 21197500 gaines.west@westwebb.law 1/23/2025 5:10:05 AM SENT
John Rudinger 24067852 jay.rudinger@westwebblaw.com 1/23/2025 5:10:05 AM SENT
Judd Stone 24076720 Judd@stonehilton.com 1/23/2025 5:10:05 AM SENT
Daniel Olds 24088152 dolds@clarkhill.com 1/23/2025 5:10:05 AM SENT
Brooke Noble bnoble@velaw.com 1/23/2025 5:10:05 AM SENT
Michael Graham 24113581 Michael.Graham@TEXASBAR.COM 1/23/2025 5:10:05 AM SENT
Emily Bamesberger ebamesberger@velaw.com 1/23/2025 5:10:05 AM SENT
Justin B.Cox jbcox@clarkhill.com 1/23/2025 5:10:05 AM SENT
Gaines West gaines.west@westwebblaw.com 1/23/2025 5:10:05 AM SENT