GRANTED PD-1053-19 COURT OF CRIMINAL APPEALS PER CURIAM AUSTIN, TEXAS Transmitted 12/9/2020 2:05 PM 12/14/2020 Accepted 12/10/2020 9:26 AM NO. PD-1053-19 DEANA WILLIAMSON CLERK IN THE COURT OF CRIMINAL APPEALS FILED OF TEXAS COURT OF CRIMINAL APPEALS 12/10/2020 DEANA WILLIAMSON, CLERK ALLEN BRAY PUGH Appellant, v. THE STATE OF TEXAS, Appellee. On Appeal from the 42nd District Court of Taylor County, Texas Cause No. 26281-A (Hon. James Eidson) and Cause No. 11-17-00216-CR from the COURT OF APPEALS FOR THE ELEVENTH JUDICIAL DISTRICT EASTLAND, TEXAS __________________________________________________________________ JEFFREY A. PROPST’S MOTION TO WITHDRAW AS COUNSEL TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: Now comes Jeffrey A. Propst, co-counsel for Allen Bray Pugh, and files this Motion to Withdraw as Counsel. CAUSE FOR WITHDRAWAL Withdrawal of counsel is permissible when withdrawal can be accomplished without material adverse effect on the interests of the client. TEX. DISC. R. OF PROF’L CONDUCT 1.15(b)(1). Withdrawal of counsel in this case can be accomplished without material adverse effect on the interests of Mr. Pugh, because Mr. Pugh can rely on co-counsel, Rick Dunbar, who is listed as an attorney of record in this case and in the case from the appellate court. Further, other good cause for withdrawal exists. See TEX. DISC. R. OF PROF’L CONDUCT 1.15(b)(7). Specifically, Jeffrey A. Propst is permanently closing his law practice in December 2020 to assume the role of District Judge in the 104th District Court of Taylor County, Texas, on January 1, 2021. CONSENT OF MR. PUGH Mr. Pugh has been informed of the circumstances and the need for Jeffrey A. Propst to withdraw. Mr. Pugh consents to the withdrawal as is evidenced by the attached consent form. DEADLINES There are currently no deadlines in this case. The case was submitted by oral argument and is awaiting decision. PRAYER WHEREFORE, PREMISES CONSIDERED, Jeffrey A. Propst asks this Honorable Court to issue an order discharging him from the case as attorney for Allen Bray Pugh. Respectfully submitted, _________________________________ JEFFREY A. PROPST Texas Bar No. 24064062 P.O. Box 3717 Abilene, Texas 79604 Tel. (325) 455-1599 Fax (325) 455-1507 Email: jeff@keithandpropst.com CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the following on November 23, 2020: Allen Bray Pugh, Appellant by mail to TDCJ - Hughes Unit Britt Lindsey, Attorney for the State of Texas by email Rick Dunbar, Attorney for Appellant by email ___________________________________ JEFFREY A. PROPST CERTIFICATE OF COMPLIANCE I hereby certify that according to the word count function of the word processing software used to draft this motion, the word count is 421 words. ___________________________________ JEFFREY A. PROPST Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Jeffrey Propst on behalf of Jeffrey Propst Bar No. 24064062 jeff@keithandpropst.com Envelope ID: 48789952 Status as of 12/10/2020 9:27 AM CST Associated Case Party: AllenBrayPugh Name BarNumber Email TimestampSubmitted Status Jeffrey Propst jeff@keithandpropst.com 12/9/2020 2:05:36 PM SENT Rick Dunbar rickdunbar2013@gmail.com 12/9/2020 2:05:36 PM SENT Associated Case Party: State Name BarNumber Email TimestampSubmitted Status Britt Lindsey lindseyb@taylorcountytexas.org 12/9/2020 2:05:36 PM SENT Stacey Soule information@spa.texas.gov 12/9/2020 2:05:36 PM SENT