in the Matter of the Marriage of Amanda Bradshaw and Barney Bradshaw

FILED hM
RECEIVED IN
The '-'..-urt of Aopeals
CASE NO. 06-15-00038-CV The Court of Appeals
Sixth District Sixth District
AUG 1 3 2015 IN THE
AUG 1 3 2015
COURT OF APPEALS FOR THE
"i3>:arfcana, Texas *
Debra Auirey, Clerk SIXTH DISTRICT OF TEXAS Texarkana, Texas
AT TEXARKANA, TEXAS Debra K, Autrey, Clerk

IN THE MATTER OF THE MARRIAGE OF

AMANDA CHERI BRADSHAW
Petitioner/Appellant
AND

BARNEY SAMUEL BRADSHAW
Respondent/Appellee

Appeal from the County Court at Law
Rusk County, Texas
Cause No. 2013-09-482-CCL
The Honorable Chad Dean, Presiding

APPELLEE'S MOTION FOR RECUSAL
AND TRANSFER

TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS:

COMES NOW, BARNEY SAMUEL BRADSHAW, Respondent/Appellee in

the above-referenced case and submits his motion for recusal and

transfer. In support of said motion Appellee shows the Court the

following.

I.

Appellee objects to the hearing and deciding of this case by
Chief Justice Josh R. Morriss, III, Justice Bailey C Moseley and
Justice Ralph K. Burgess. Said Justices rendered the judgment and
opinion in Appellee's criminal case in Case No. 06-14-00165-CR,
which was entered into evidence in this case by Appellant in her

Motion to Reopen Evidence as Exhibit B. Appellee believes that a

conflict of interest exists and that said Justices may not act in

an impartial manner.

II.

This case has been previously appealed to the Court of Ap

peals for the Twelth District of Texas in Case No. 12-14-00056-CV.

Said Court is already familiar with this case and had issued:.ai.

judgment reversing and remanding the trial court's judgment for

further proceedings.

III.

Appellee believes that Appellant has filed her appeal in this

Court for the sole purpose of gaining an advantage due to Appellee's
criminal appeal.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellee, Barney Samuel Brad-

shaw, prays that the Court grant this motion and each of said

Justices recuse themselves from this case. Appellee further prays

that this case is transfered back to the Court of Appeals for the

Twelfth District of Texas.

Respectfully submitted,

BARNEY SAMUEL BRADSHAW
APPELLEE
TDCJ No. 01942978
Mark W. Michael Unit
2664 FM 2054
Tennessee Colony, Texas 75886
 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the fore

going motion has been served by placing same in the United States

Mail, postage prepaid, on this 10th day of August, 2015, addressed

to Ebb B. Mobley, Attorney for Appellant, P.O. Box 2309, Longview,

Texas 75606.

BARNEY SAMUEL BRADSHAW
APPELLEE