Ruben Maldonado v. State

Opinion

ACCEPTED 01-15-00635-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 11/9/2015 10:23:13 AM CHRISTOPHER PRINE CLERK

APPEAL NO. 01-15-00635-CR __________________________ FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS FIRST JUDICIAL DISTRICT AT HOUSTON, TEXAS11/9/2015 10:23:13 AM __________________________ CHRISTOPHER A. PRINE Clerk RUBEN MALDONADO, Appellant,

Vs.

THE STATE OF TEXAS, Appellee. __________________________

ATTORNEY PATRICK F. McCANN’S MOTION TO WITHDRAW AS COUNSEL OF RECORD

TO THE HONORABLE JUSTICES OF THE 14TH COURT OF APPEALS:

Appointed counsel of record, Patrick F. McCann, respectfully moves this

Honorable Court to GRANT him leave to withdraw as counsel of record in this

appeal. In support of such motion, Appellant would show the Court the following:

(1) Mr. Maldonado executed a paupers oath, and the undersigned counsel

was appointed to represent him in this appeal. (Attachment A).

(2) On August 20, 2015, the Honorable F. Clinton Broden “enter[ed] his

appearance on behalf of Appellant Ruben Maldonado” in this appeal. (Attachment

B). (3) The undersigned counsel is still listed as counsel of record in this

matter, and receiving notices concerning the appeal.

(3) Withdrawal can be accomplished without material adverse effect on

the interests of the client and without unnecessarily delaying the due administration

of justice.

CONCLUSION AND PRAYER

WHEREFORE, PREMISES CONSIDERED, Movant, Patrick F. McCann,

respectfully requests that the Court will, in all things, GRANT his motion and

withdraw his name as attorney of record in the above styled and numbered cause.

DATED this 9th day of November, 2015.

Respectfully Submitted,

/s/ Patrick F. McCann State Bar No. 00792680 Law Office of Patrick F. McCann Suite 205, Rice Hotel 909 Texas Avenue Houston, Texas 77002 (713) 223-3805 eFax:

Counsel of Record for the Appellant CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foreging

ATTORNEY PATRICK F. McCANN’S MOTION TO WITHDRAW AS

COUNSEL OF RECORD has been duly served upon counsel representing the

State of Texas in this matter by either Hand Delivery, Prepaid United States Mail

(Appellant Maldonado), E-mail, Facsimile (Broden Esq.), or through

this Court’s Electronic Filing System (Curry, Esq.) on this 9th day of November,

2015, addressed as follows:

Allen Curry, Esq. Assistant District Attorney Harris County, Texas 1201 Franklin, Sixth Floor Houston, Texas 77002

F. Clinton Broden, Esq. Broden, Mickelson, Helms & Snipes 2600 State Street Dallas, Texas 75204 FAX: (214) 720-9594

Ruben Maldonado TDC# 2011367 Polunsky Unit 3872 FM 350 South Livingston, TX 77351

/s/ Patrick F. McCann ATTACHMENT A Un off icia lC op yO ffic eo fC hri sD an iel D ist ric tC ler k ATTACHMENT B ACCEPTED 01-15-00635-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 8/20/2015 11:38:04 AM CHRISTOPHER PRINE CLERK

COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS HOUSTON, TEXAS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS RUBEN MALDONADO, ) 8/20/2015 11:38:04 AM ) CHRISTOPHER A. PRINE Clerk Appellant, ) CAUSE NO ) 01-15-00635-CR ) V. ) ) STATE OF TEXAS, ) ) Appellee. ) ___________________________________ )

ENTRY OF APPEARANCE

F. Clinton Broden of the Law Firm Broden, Mickelsen, Helms & Snipes, LLP

hereby enters his appearance on behalf of Appellant Ruben Maldonado in the above

referenced case.

/s/ F. Clinton Broden F. Clinton Broden Tx. Bar 24001495 Broden, Mickelsen, Helms & Snipes, LLP 2600 State Street Dallas, TX 75204 (214) 720-9552 (214) 720-9594 (facsimile)

Attorney for Appellant Ruben Maldonado CERTIFICATE OF SERVICE

I, F. Clinton Broden, certify that on August 20, 2015, I caused a copy of the

above document to be mailed by first class mail, postage prepaid, on the Harris

County District Attorney’s Office, 1201 Franklin Street, Suite 600, Houston, Texas

77002-1923.

/s/ F. Clinton Broden F. Clinton Broden