COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/30/2014 12:20:19 PM
Accepted 12/30/2014 3:56:52 PM
IN THE TEXAS COURT OF CRIMINAL APPEALS ABEL ACOSTA
AUSTIN, TEXAS CLERK
LAWREN CE DONOVAN
APPELLANT
December 31, 2014
v. No. PD-0474-14
THE STATE OF TEXAS
APPELLE
COUNSELS MOTION TO PERMIT LEAD COUNSEL TO WITHDRAWAL AND
SUBUSTITUTION OF LEAD COUNSEL ON APPEAL
Lead Counsel, David L. Richards, pursuant to appellate rule 6.5 (d), moves the Court to
permit him, to withdraw from further representation on appeal, and requests that honorable John
Hill Cayce, State Bar No. 04035650, to substitute as lead counsel in his place showing the Court
the following:
I.
David L. Richards is leaving private practice, effective January 1, 2015, in the anticipation
he will be entering government service the following day.
II.
Continued representation past January 1, 2015, would constitute a conflict of interest.
The substitution of lead counsel is necessary to ensure Appellant receives effective assistance of
counsel on appeal.
III.
John Cayce's contact information is: 201 Main Street, Suite 200, Fort Worth, Texas
76102, Phone: (817) 878-3597, Fax: (817) 878-9797, State Bar No. 04035650.
IV.
A copy of this Motion is being delivered to appellate by both certified mail and regular
mail this 30th day of December 2014. There are no current deadlines to be met, and the appeal is
currently awaiting the issuance of an opinion from this court.
Wherefore, Counsel asks that this Motion be granted.
Respectfully Submittj? •
/)14M.· J ~~ ........
David Richards
State Bar No. 16845500
3001 West 5th Street, Suite 800
Fort Worth, Texas 76107
Phone: (817) 332-5567
Fax: (817) 885 -7688
CERTIFICATE OF CONFERENCE AND SERVICE
The undersigned, David Richards, certifies that that a true copy of this document has been
e-served this day to the appellate division of the Tarrant County District Attorney's Office, a
member of which (Charles Mallin) has indicated they have no opposition to its granting, this 30th
day of December 2014.
David Richards