Donovan, Lawrence ( 2014 )

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/30/2014 12:20:19 PM Accepted 12/30/2014 3:56:52 PM IN THE TEXAS COURT OF CRIMINAL APPEALS ABEL ACOSTA AUSTIN, TEXAS CLERK LAWREN CE DONOVAN APPELLANT December 31, 2014 v. No. PD-0474-14 THE STATE OF TEXAS APPELLE COUNSELS MOTION TO PERMIT LEAD COUNSEL TO WITHDRAWAL AND SUBUSTITUTION OF LEAD COUNSEL ON APPEAL Lead Counsel, David L. Richards, pursuant to appellate rule 6.5 (d), moves the Court to permit him, to withdraw from further representation on appeal, and requests that honorable John Hill Cayce, State Bar No. 04035650, to substitute as lead counsel in his place showing the Court the following: I. David L. Richards is leaving private practice, effective January 1, 2015, in the anticipation he will be entering government service the following day. II. Continued representation past January 1, 2015, would constitute a conflict of interest. The substitution of lead counsel is necessary to ensure Appellant receives effective assistance of counsel on appeal. III. John Cayce's contact information is: 201 Main Street, Suite 200, Fort Worth, Texas 76102, Phone: (817) 878-3597, Fax: (817) 878-9797, State Bar No. 04035650. IV. A copy of this Motion is being delivered to appellate by both certified mail and regular mail this 30th day of December 2014. There are no current deadlines to be met, and the appeal is currently awaiting the issuance of an opinion from this court. Wherefore, Counsel asks that this Motion be granted. Respectfully Submittj? • /)14M.· J `` ........ David Richards State Bar No. 16845500 3001 West 5th Street, Suite 800 Fort Worth, Texas 76107 Phone: (817) 332-5567 Fax: (817) 885 -7688 CERTIFICATE OF CONFERENCE AND SERVICE The undersigned, David Richards, certifies that that a true copy of this document has been e-served this day to the appellate division of the Tarrant County District Attorney's Office, a member of which (Charles Mallin) has indicated they have no opposition to its granting, this 30th day of December 2014. David Richards