ACCEPTED
01-15-00487-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/24/2015 3:29:17 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00487-CR
IN THE COURT OF APPEALS FILED IN
)
1st COURT OF APPEALS
HOUSTON, TEXAS
FIRST DISTRICT
8/24/2015 3:29:17 PM
CHRISTOPHER A. PRINE
HOUSTON, TEXAS Clerk
NO. 1416994
IN THE TRIAL COURT
230TH JUDICIAL DISTRICT
HARRIS COUNTY, TEXAS
FREDIS MAURICIO FLORES § APPELLANT
vs. §
THE STATE OF TEXAS § APPELLEE
MOTION TO SUBSTITUTE COUNSEL
ON APPEAL
ALLEN C. ISBELL
2016 Main St., Suite 110
Houston, Texas 77002
(713) 236-1000
Fax No. (713) 236-1809
STATE BAR NO. 10431500
email: allenisbell@sbcglobal.net
COUNSEL ON APPEAL
TO THE HONORABLE COURT OF APPEALS:
COMES NOW ALLEN C. ISBELL and respectfully requests this
Honorable Court grant his motion to substitute as counsel on appeal for
appellant, FREDIS MAURICIO FLORES. For cause, appellant would show
the Court as follows:
I.
On May 14, 2015, appellant was convicted of the offense of Driving
While Intoxicated (3rd Offender), in Cause No. 1416994, in the 230th District
Court of Harris County, Texas entitled The State of Texas vs. Fredis Mauricio
Flores. The trial court appointed Attorney J. Celeste Carter Blackburn to
represent appellant on appeal.
II .
On August 24, 2015, ALLEN C. ISBELL was retained to represent
appellant on appeal. Appointed Counsel consents to the substitution of
ALLEN C. ISBELL as counsel on appeal for Fredis Mauricio Flores.
II I.
This motion is urged at the first opportunity and is not sought for
purposes of delay but so that justice may be served.
c:\appeals\flores\mtn . to substitute counsel on appeal 2
WHEREFORE, PREMISES CONSIDERED, appellant prays that this
Honorable Court grant this motion to substitute counsel on appeal and
substitute ALLEN C. ISBELL as appellate counsel for Fredis Mauricio Flores
on appeal.
Respectfully submitted,
Isl Allen C. Isbell
ALLEN C. ISBELL
2016 Main St. , Suite 110
Hou~on , Texas77002
(713) 236-1000
Fax No. (713) 236-1809
STATE BAR NO. 10431500
email: allenisbell@sbcglobal.net
COUNSEL ON APPEAL
AGREED AND APPROVED:
7'9.cEQt/~R~~µ
Attorney at Law
333 N. Rivershire Dr. , Suite 285
Conroe, Texas 77304
(936) 703-5000
Fax No. (877) 900-2822
ST~T~ BAR NO. 24038803
~ 8-i'~ 1 ~ht-.~;-t/r>-
c:\appeals\flores\mtn . to substitute counsel on appeal 3
Certificate of Service
I hereby certify that on this 24th day of August, 2015, a true and correct
copy of the foregoing Motion for Substitution of Counsel on Appeal has been
sent to the District Attorney's Office, Appellate Division, and to Mr. Fredis
Mauricio Flores, appellant.
Isl Allen C. Isbell
ALLEN C. ISBELL
Certificate of Compliance
The undersigned attorney on appeal certifies this motion is computer
generated and consists of 418 words. Counsel is relying on the word count
provided by the Word Perfect computer software used to prepare the motion.
Isl Allen C. Isbell
ALLEN C. ISBELL
c:\appeals\flores\mtn . to substitute counsel on appeal 4