ACCEPTED
03-12-00631-CV
4700848
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/30/2015 5:09:56 PM
JEFFREY D. KYLE
CLERK
THIRD COURT OF APPEALS FILED IN
FOR THE STATE OF TEXAS 3rd COURT OF APPEALS
AUSTIN, TEXAS
3/30/2015 5:09:56 PM
STATE OF TEXAS JEFFREY D. KYLE
Clerk
VS.
No. 03-12-00631-CV
CAROLYN BARNES
MOTION TO WITHDRAW AS COUNSEL
Mr. Shannon Hooks, attorney of record in the above case, hereby
moves this court to allow counsel to withdraw from representing the
appellant for the following reasons:
Appellant has filed a civil lawsuit in Travis County, Texas, (Cause no.
D-1-GN-15-000877) naming counsel as one of the defendants. Counsel is
required to respond to the civil petition within 20 days.
Counsel strongly believes that defending himself in the civil lawsuit
while continuing to represent the appellant in this case will result in
prejudice to both parties in their respective cases. Counsel therefore
requests that this court allow present counsel to withdraw as attorney in this
case, so that new counsel can be appointed to represent the appellant
regarding all future rights of appeal.
Counsel hereby certifies that he has sent by certified mail and first
class mail to appellant Carolyn Barnes, 419 Indian Trail, Leander, Texas
78641, her last known address, a copy of this Motion along with a letter
informing her of her right to object to the Motion.
Respectfully submitted,
/s/Shannon Hooks
Shannon C. Hooks #24045001
Attorney for Appellant
6910 Hart Lane #510
Austin, Texas 78731
Certification of Conference with Opposing Counsel
Counsel hereby certifies that today, March 30, 2015, he has conferred
with attorney John Prezas, of the Williamson County District Attorney‘s
Office regarding this Motion. Mr. Prezas has informed counsel that he has
no objection to counsel’s Motion to Withdraw.
CERTIFICATE OF SERVICE
I, Shannon Hooks, hereby certify that a true and exact copy of the
foregoing has been sent via U.S. Mail Service to the Williamson County
Attorney’s office on this 30th day of March 2015.
/s/Shannon Hooks
Shannon Hooks
Carolyn Barnes v. State
Combined Opinion