Home/Court of Appeals of Texas/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

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

Court of Appeals of Texas·Decided January 31, 2025·No. 15-24-00095-CV·Published

Opinion

ACCEPTED

15-24-00095-CV

FIFTEENTH COURT OF APPEALS Court of Appeals Number: 15-24-00095-CV AUSTIN, TEXAS 1/31/2025 6:12 AM

CHRISTOPHER A. PRINE

Trial Court Case Number: D-1-GN-24-002025 CLERK RECEIVED IN

15th COURT OF APPEALS

AUSTIN, TEXAS

Edward Rudolph Turnbull, IV 1/31/2025 6:12:05 AM v. IN THE COURTCHRISTOPHER OF APPEALS A. PRINE

Clerk

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.

THIRD AMICI CURIAE BRIEF BY ADRIANO KRUEL BUDRI, CITIZEN, AND IN SUPPORT OF APPELLANT EDWARD RUDOLPH TURNBULL, IV OF SEEKING ACCOUNTABILITY OF THE INCUMBENT CHIEF DISCIPLINARY COUNSEL SEANA BECKERMAN WILLIAM OF THE STATE BAR OF TEXAS IN HER INDIVIDUAL AND OFFICIAL CAPACITY FOR ULTRA VIRES ACTS PERPETRATED IN ONE GRIEVANCE COMPLAINT ASSIGNED AND DISMISSED FOR NO “JUST CAUSE” AND WITHOUT TO PROVIDE A FULL EXPLANATION TO COMPLAINANT AS REQUIRED BY THE STATUTE “STATE BAR ACT” AND THE TEXAS GOVERNMENT CODE PROVISIONS

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TABLE OF CONTENTS

TABLE OF AUTHORITIES............................................................................ iii INTEREST OF AMICUS CURIAE............................................................... 4 AMICUS CURIAE CITIZEN’S STATEMENT……………………………… 5 SUMMARY OF ARGUMENT………………………………………..……… 5 ARGUMENT…………………………………………………………………. 6 I. Appellant seeks impartial and with integrity investigation and disclosures of a disturbing pattern of Chief Disciplinary Counsel’s misconduct, implicating flagrant violation of the state statute “State Bar Act” and codified by the Texas Government Code for authorized practice of law in Texas, but have not questioned the eligibility of the Chief Disciplinary Counsel as State Judicial Official as State Administrative Agency Prosecutor in the Judicial Branch Entity of the State Government of the State of Texas as eligible office holder and holding a statewide public office as part of the statewide administrative agency of the judicial branch entity of the State Government of the State of Texas as one State Government Employee as unclassified employee and appointed as ex-officio official by the Board of Officer and Directors of the State Bar of Texas as Government Unit in the judicial branch of the state government of the State of Texas…………………………………. 6 CONCLUSION………………………………………………………………… 9 CERTIFICATE OF SERVICE……………………………………………….. 10

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TABLE OF AUTHORITIES

Texas Rules Appellate Procedure (TRAP) Texas Constitution, Article XVI, Section 1……………………………… passim

Texas Government Code, Chapter 603 and amended by adding Section 602.007……………………………………………………………………… 6 State Law State Law SB 1329 for Oaths of Office and Requirements for Oaths of Office and Anti-Bribery Statements, Article 4 for Judicial Oaths, Section passim

4.01…………………………………………………………………………

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INTEREST OF AMICUS CURIAE This brief is about those obstacles, and why the Appellant is seeking relief in this civil appellate case and that is particularly crucial for the execution of the accountability of the state government employees allotted in state government agencies and having paraphernalia of immunities and to assure unaccountability from Ultra Vires acts committed in secretive administrative quasi judicial proceedings and from unclear legible office holders as Judicial Officials of the State Bar of Texas and that is one Statewide Public Corporation and one Statewide Administrative Agency in the Judicial Branch Entity of the State Government of the State of Texas.

Amicus respectfully brings to the Court’s attention about the ramifications and implications of the pattern or defiance practice adopted by the Chief Disciplinary Counsel (“CDC”) in her individual and official capacity and under an unethical internal policy labeled by the CDC as “weeded out” policy and for approximately 90% of the summary dismissals executed and from grievance forms submitted by Complainants with the Office of the Chief Disciplinary Counsel of the State Bar of Texas at Austin’s Headquarters Office and also being dismissed as no “just cause” from Summary Disposition Panels (“SDPs”) from grievance committee districts of the State Bar of Texas and executing the functionality as

Judicial Officials in one Committee that is part integrant of the administrative structure of the State Bar of Texas as part of the Judicial Branch Entity of the State Government of the State of Texas.

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 amicus curiae brief and submitted on 01/20/2025, Monday via electronic filing EFILETX system in the case number assigned: 15-24-00095-CV and filed at the Court of Appeals 15th District of Texas at Austin.

SUMMARY OF ARGUMENT

In light of the fact that the Texas Judicial Council Legislative in the 85th R.

S. dated on 06/30/2017 with the State Law SB 1329 for Oaths of Office and requirements for Oaths of Office and Anti-Bribery Statements have extended for all State Officials appointed by the Supreme Court of Texas, Court of Criminal Appeals and State Bar of Texas, as well as, for Associate Judges appointed for the Children’s Courts be filed with the Texas Secretary of State and including for all Board Members appointed by the Supreme Court of Texas (BODA’s Members), State Judicial Agencies as example JBCC’s Commission Members, State Administrative Agencies as example the State Bar of Texas and from the Judicial Officials and for Judicial Oaths and requiring the Oath of Office and the signed

Statement required by the Texas Constitution, Article XVI, Section 1 of certain individuals to be filed with the Texas Secretary of State; the State Law Number 1329 has prescribed in the Article 4 for Judicial Oaths, Section 4.01, Chapter 603, Texas Government Code and amended by adding Section 602.007 to read as follows: Section 602.007 for filing of Oath made by certain Judicial Officers and Judicial Appointees that the Oath made and signed statement executed as required by Section 1, Article XVI, Texas Constitution by any of the following Judicial Officers and Judicial Appointees shall be filed with the Texas Secretary of State: (1) An Officer appointed by the Supreme Court of Texas, the Court of Criminal Appeals or by the State Bar of Texas; and (2) An Associate Judge appointed under Subchapter B or C, Chapter 201, Family Code and having been enacted and signed by the Texas Governor on 06/15/2017.

ARGUMENT

I. Appellant seeks impartial and with integrity investigation and disclosures of a disturbing pattern of Chief Disciplinary Counsel’s misconduct, implicating flagrant violation of the state statute “State Bar Act” and codified by the Texas Government Code for authorized practice of law in Texas, but have not questioned the eligibility of the Chief Disciplinary Counsel as State Judicial Official as State Administrative Agency Prosecutor in the Judicial Branch Entity of the State Government of the State of Texas as eligible office holder and holding a statewide public office as part of the statewide administrative agency of the judicial branch entity of the State Government of the State of Texas as one State Government Employee as

unclassified employee and appointed as ex-officio official by the Board of Officer and Directors of the State Bar of Texas as Government Unit in the judicial branch of the state government of the State of Texas.

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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, (Tex. Ct. App. 2025).

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 (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) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.