Ruben Maldonado v. State ( 2015 )

ACCEPTED
01-15-00635-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/9/2015 10:23:13 AM
CHRISTOPHER PRINE
CLERK
APPEAL NO. 01-15-00635-CR
__________________________
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS
FIRST JUDICIAL DISTRICT AT HOUSTON, TEXAS11/9/2015 10:23:13 AM
__________________________ CHRISTOPHER A. PRINE
Clerk
RUBEN MALDONADO,
Appellant,
Vs.
THE STATE OF TEXAS,
Appellee.
__________________________
ATTORNEY PATRICK F. McCANN’S MOTION TO
WITHDRAW AS COUNSEL OF RECORD
TO THE HONORABLE JUSTICES OF THE 14TH COURT OF APPEALS:
Appointed counsel of record, Patrick F. McCann, respectfully moves this
Honorable Court to GRANT him leave to withdraw as counsel of record in this
appeal. In support of such motion, Appellant would show the Court the following:
(1) Mr. Maldonado executed a paupers oath, and the undersigned counsel
was appointed to represent him in this appeal. (Attachment A).
(2) On August 20, 2015, the Honorable F. Clinton Broden “enter[ed] his
appearance on behalf of Appellant Ruben Maldonado” in this appeal. (Attachment
B).
(3) The undersigned counsel is still listed as counsel of record in this
matter, and receiving notices concerning the appeal.
(3) Withdrawal can be accomplished without material adverse effect on
the interests of the client and without unnecessarily delaying the due administration
of justice.
CONCLUSION AND PRAYER
WHEREFORE, PREMISES CONSIDERED, Movant, Patrick F. McCann,
respectfully requests that the Court will, in all things, GRANT his motion and
withdraw his name as attorney of record in the above styled and numbered cause.
DATED this 9th day of November, 2015.
Respectfully Submitted,
/s/ Patrick F. McCann
State Bar No. 00792680
Law Office of Patrick F. McCann
Suite 205, Rice Hotel
909 Texas Avenue
Houston, Texas 77002
(713) 223-3805
eFax:
Counsel of Record for the
Appellant
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foreging
ATTORNEY PATRICK F. McCANN’S MOTION TO WITHDRAW AS
COUNSEL OF RECORD has been duly served upon counsel representing the
State of Texas in this matter by either Hand Delivery, Prepaid United States Mail
(Appellant Maldonado), E-mail, Facsimile (Broden Esq.), or through
this Court’s Electronic Filing System (Curry, Esq.) on this 9th day of November,
2015, addressed as follows:
Allen Curry, Esq.
Assistant District Attorney
Harris County, Texas
1201 Franklin, Sixth Floor
Houston, Texas 77002
F. Clinton Broden, Esq.
Broden, Mickelson, Helms & Snipes
2600 State Street
Dallas, Texas 75204
FAX: (214) 720-9594
Ruben Maldonado
TDC# 2011367
Polunsky Unit
3872 FM 350 South
Livingston, TX 77351
/s/ Patrick F. McCann
ATTACHMENT A
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ATTACHMENT B
ACCEPTED
01-15-00635-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/20/2015 11:38:04 AM
CHRISTOPHER PRINE
CLERK
COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS
HOUSTON, TEXAS
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
RUBEN MALDONADO, ) 8/20/2015 11:38:04 AM
) CHRISTOPHER A. PRINE
Clerk
Appellant, ) CAUSE NO
) 01-15-00635-CR
)
V. )
)
STATE OF TEXAS, )
)
Appellee. )
___________________________________ )
ENTRY OF APPEARANCE
F. Clinton Broden of the Law Firm Broden, Mickelsen, Helms & Snipes, LLP
hereby enters his appearance on behalf of Appellant Ruben Maldonado in the above
referenced case.
Respectfully submitted,
/s/ F. Clinton Broden
F. Clinton Broden
Tx. Bar 24001495
Broden, Mickelsen, Helms & Snipes, LLP
2600 State Street
Dallas, TX 75204
(214) 720-9552
(214) 720-9594 (facsimile)
Attorney for Appellant
Ruben Maldonado
CERTIFICATE OF SERVICE
I, F. Clinton Broden, certify that on August 20, 2015, I caused a copy of the
above document to be mailed by first class mail, postage prepaid, on the Harris
County District Attorney’s Office, 1201 Franklin Street, Suite 600, Houston, Texas
77002-1923.
/s/ F. Clinton Broden
F. Clinton Broden