AETC II Privatized Housing, LLC v. Tom Green County Appraisal District

ACCEPTED
03-13-00463-CV
8059721
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/2/2015 4:20:42 PM
JEFFREY D. KYLE
CLERK

No. 03-13-00463-CV FILED IN
3rd COURT OF APPEALS
In The Court Of Appeals AUSTIN, TEXAS
For The Third Court Of Appeals District 12/2/2015 4:20:42 PM
JEFFREY D. KYLE
Austin, Texas Clerk

AETC II PRIVATIZED HOUSING, LLC
Appellant,
V.

TOM GREEN COUNTY APPRAISAL DISTRICT
Appellee.

ON APPEAL FROM THE 391ST DISTRICT COURT, TOM GREEN COUNTY, TEXAS
TRIAL COURT CAUSE NO. D-10-0377-C

APPELLANT'S MOTION FOR SUBSTITUTION
OF COUNSEL

BRUSNIAK LAW, PLLC
Tracy Turner
Texas Bar No. 24076743
tracy@txtax.com
Three Galleria Tower
13155 Noel Road, Suite 1850
Dallas, Texas 75240
Telephone: (972) 250-6363
Facsimile: (972) 250-3599

Counsel for Appellants
 COMES NOW, AETC II PRIVATIZED HOUSING, LLC,

Appellant in the above numbered and entitled cause, and pursuant to Rule 10 of the Texas Rules

of Civil Procedure, respectfully asks the Court to substitute the law firm of Brusniak Law, PPLC

and attorneys John Brusniak, Jr., Kory L. Ryan, and Tracy M. Turner as attorneys of record for

the Appellant. John Brusniak, Jr., Kory L. Ryan, and Tracy M. Turner were previously

representing the Appellant at Ryan Law Firm, LLP but have since left and formed Brusniak Law,

PLLC. These are the same lawyers that were previously handling the lawsuit for Appellant, and

will continue to represent the Appellant at Brusniak Law, PLLC.

I.
Pursuant to rule 10 of the Texas Rules of civil Procedure, Appellant's new attorney of
record's information is as follows:
John Brusniak, Jr.
State Bar No. 03261500
john@txtax.com
KoryL. Ryan
State Bar No. 24068065
Kory@txtax.com
Tracy M. Turner
State Bar No. 24076743
tracy@txtax.com

BRUSNIAKLAW, PLLC
Three Galleria Tower
13155 Noel Rd., Suite 1850
Dallas, Texas 75240
Ph: (972) 250-6363
Fax: (972) 250-3599

II.

Appellant approves of the substitution of the law firm ofBrusniak Law, PPLC in place and

stead of the law firm of Ryan Law firm, LLP as its counsel of record.

Motion for Substitution of Counsel--Page I
 III.

This substitution is not sought for delay and will not be used as a basis for delaying the

setting of this case.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests the Court to

enter an Order substituting the law firm ofBrusniak Law,.PLLC in place and stead of the law firm

of Ryan Law Firm, LLP, as its counsel ofrecord in this matter and for such other and further relief

to which it may be justly entitled.

Respectfully submitted,

BRUSNIAK LAW, PLLC
Three Galleria Tower
13155 Noel Rd., Suite 1850
Dallas, Texas 75240
Ph: (972) 250-6363
Fax: (972) 250-3599

By: ls/TRACY M TURNER
John Brusniak, Jr.
State Bar No. 03261500
KoryL. Ryan
State Bar No. 24068065
Tracy M. Turner
State Bar No. 24076743

ATTORNEYS FOR APPELLANTS

Motion for Substitution of Counsel--Page 2
 Certificate of Conference

On October 28, 2015, a conference was held with counsel for Appellee, concerning the
merits of this motion. Counsel for Appellee is not opposed to this motion.

On October 28, 2015, a conference was held with Ryan Law Firm, LLP, concerning the
merits of this motion. Ryan Law Firm, LLP is not opposed to this motion.

Isl Tracy M Turner
Tracy M. Turner

Certificate of Service

I certify that a copy of the foregoing Motion for Substitution of Counsel was served on
Defendant, Tom Green County Appraisal District, through counsel of record, James Robert
Evans, Jr., Hargrove & Evans, LLP, 4425 Mopac South, Building 3, Suite 400, Austin, Texas
78735, jim@hellplaw.com, by electronic service through Efiletx.gov on December 2, 2015.

Isl Tracy M Turner
Tracy M. Turner

Motion/or Substitution o/Cou11se/--Page 3