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