Daniel Shoemaker v. State of Texas for the Protection of C.L. ( 2015 )

ACCEPTED
01-15-00371-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/18/2015 10:48:47 AM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00371-CV
FILED IN
IN THE FIRST COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
FOR THE STATE OF TEXAS 12/18/2015 10:48:47 AM
CHRISTOPHER A. PRINE
Clerk
DANIEL SHOEMAKER
Appellant
V.
CAMILLE LATOUR
Appellee
On Appeal From County Court at Law Number Four of Travis County Texas
APPELLANT’S UNOPPOSED MOTION TO FILE AMENDED BRIEF
CHRISTOPHER BEAN & ASSOCIATES
Attorney for Appellant
Brian Buster
SBN: 24082757
Christopher Bean
SBN: 24012263
1301 S IH-3 5 N, Suite 105
Austin, Texas 78741
TEL: (512)-916-9956
FAX: (512)-669-5282
TRAVIS COUNTY ATTORNEY
Attorney for Appellee
Hilary L. Riley
SBN: 24013404
P.O. Box 1748
Austin, Texas 78767
TEL: (512)-854-4163
FAX: (512)-854-9570
TO THE HONORABLE FIRST COURT OF APPEALS:
1. Pursuant to TEX. R. APP. P. §38.7, the Appellant, Daniel Shoemaker, files this Unopposed
Motion to File Amended Brief.
2. Appellant’s opening brief was filed with this Court on October 5, 2015.
3. Counsel for Appellant requests that this Court allow Appellant to file an amended brief in
this cause.
4. The attached amended brief is substantively exactly the same as the brief filed with this
Court on October 5, 2015, but Counsel for Appellant noticed that the page numbers in the brief
did not correspond to the table of contents due to a formatting error and that the appendix
required by TEX. R. APP. P. §38.1 was missing. Appellant respectfully asks to file this amended
brief to comply with TEX. R. APP. P. §38.1 and to make the brief more coherent with regard to
matching page numbers. Again, nothing substantive in Appellant’s arguments and authorities has
changed.
5. The undersigned has conferred with opposing counsel, and she has indicated that she
does not oppose this motion.
6. All facts recited in this motion are within the personal knowledge of Counsel for
Appellant, therefore no verification is necessary under TEX. R. APP. P. §10.2
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant this Unopposed
Motion to File Amended Brief and accept the Amended Brief and Appendix A provided with
this Motion. Appellant further requests that this Court grant all other relief to which he may be
justly entitled.
[SIGNATURE ON FOLLOWING PAGE]
Respectfully submitted,
/s/ Brian Buster
Brian Buster
State Bar No. 24082757
1301 S IH-35 N, Suite 105
Austin, TX 78741
TEL: (512)-916-9956
FAX: (512)-669-5282
brian@christopherbeanlaw.com
CERTIFICATE OF CONFERENCE
I certify that I conferred with counsel for Appellee regarding this motion and that
Appellee is not opposed to this motion.
/s/ Brian Buster
Brian Buster
CERTIFICATE OF SERVICE
I certify that on this 18 day of December , 2015, a true and correct
copy of this motion was sent to opposing counsel in accordance with the Rules of Appellate
Procedure.
/s/ Brian Buster
Brian Buster