Christina Lyons v. State

ACCEPTED 03-12-00474-CR 5035791 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/27/2015 9:11:04 AM JEFFREY D. KYLE CLERK CAUSE NO. 03-12-00474-CR FILED IN CHRISTINA LYONS § IN THE TIDRD COURT 3rd COURT OF APPEALS AUSTIN, TEXAS § 4/27/2015 9:11:04 AM v. § OF APPEALS JEFFREY D. KYLE § Clerk THE STATE OF TEXAS § AUSTIN, TEXAS MOTION TO SUBSTITUTE COUNSEL FOR APPELLANT TO THE HONORABLE illDGES OF THE COURT OF APPEALS: COMES NOW CHRISTINA LYONS, the Appellant in the above styled and numbered cause, and files this Motion requesting that the Court substitute Michael C. Gross as retained counsel of record for the Appellant in this case and allow Ariel Payan to withdraw as counsel of record for the Appellant in this cause, and in support shows as follows: 1. The case is on appeal from the 22nd District Court, Hays County, Texas. 2. The style and number of the case in the trial court is State v. Christina Lyons, Cause No. CR-11-0101. 3. The Appellant was charged with the offense of capital murder. 4. Punishment was assessed at imprisonment for life. 5. This Court has set the due date for a motion for rehearing for May 18, 2015. 6. The Appellant's name and address is Christina Lyons, TDC # 1793100, Crain Unit, 1401 State School Road, Gatesville, Texas 76599-2999. 1 7. A copy of this motion has been mailed today to the above address to the Appellant by certified and by first-class mail. 8. The Appellant has requested that Michael C. Gross, 106 S. St. Mary's# 260, San Antonio, Texas 78205, (210) 354-1919, (210) 354-1920 Fax, Bar No. 08534480, substitute as counsel of record for Ariel Payan. WHEREFORE, PREMISES CONSIDERED, counsel for the Appellant prays that the Court allow Ariel Payan to withdraw as counsel of record and allow Michael C. Gross to substitute as retained counsel of record for the Appellant. Respectfully submitted, GROSS & ESPARZA, P.L.L.C. Is/ Michael C. Gross Michael C. Gross State Bar No. 08534480 106 South St. Mary's Street, Suite 260 San Antonio, Texas 78205 (210) 354-1919 (210) 354-1920 Fax Attorney for the Appellant, CHRISTINA LYONS 2 State Bar No. 0794430 1012 Rio Grande Austin, Texas 78701 (512) 478-3900 (512) 472-4102 Fax Attorney for the Appellant CHRISTINA LYONS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was ernailed to Angie D. Roberts-Huckaby, Assistant District Attorney, angie.roberts@co .hays. tx. us on the 23rd day of April 2015. /s/ Michael C. Gross 3