Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/28/2015 8:18:49 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00556-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/28/2015 8:18:49 PM CHRISTOPHER PRINE CLERK N0. 01-15-00556-CV IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS AT HOUSTON IN THE INTEREST OF S.R.-M.C., CHILD R.A.C., SR., AKA R.C., APPELLANT VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE ON APPEAL FROM THE 313 TH DISTRICT COURT OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2010-08247J UNOPPOSED MOTION FOR WITHDRAWAL OF COUNSEL

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW DONALD M. CRANE (“appellate counsel”), appointed

attorney ad litem on appeal for Appellant, R.A.C., Sr., aka R.C., respondent

father, and hereby files this Unopposed Motion for Withdrawal of Counsel.

Donald M. Crane requests the Court grant him leave to withdraw as Attorney

ad litem on appeal for Appellant R.A.C., Sr., aka R.C., in accordance with

Texas Rules of Appellate Procedure (“TRAP”) Tex. R. App. P. 6.5, and in

support would show as follows:

1. Appellate counsel forwarded correspondence dated December 29,

2015, to Appellant enclosing a copy of the Court’s Memorandum

Opinion dated November 17, 2015, (“ Memorandum Opinion“ )

by U.S. First Class Mail and Certified Mail, Return Receipt

Requested #7014 2120 0003 3959 1292 to Appellant’s last

known address:

10091 Stonybrook Circle, Apt. A

Indianapolis, Indiana 46229

(317) 912-5762.

2. Appellate counsel advised of his duty to re-evaluate the appeal to

determine the merit of further appellate action and advised that

such is frivolous. Tex. R. App. P. 62.

3. Appellate counsel further explained that Appellant on his own

may pursue a petition for review in the Supreme Court of Texas,

but that such is frivolous.

4. Appellate counsel further explained that Appellant should retain

private counsel as to the merits of pursuing a petition for review

in the Supreme Court of Texas.

5. Appellate counsel further explained that Appellant has a current

filing deadline of January 4, 2016, and that should he

pursue a petition for review in the Supreme Court of Texas, he

should first consult Tex. R. App. P. 53.

6. Appellate counsel further explained that Appellant may

Contact the Supreme Court of Texas, P.O. Box 12248,

Austin, Texas 78711, (512) 463-1312, for further information.

7. Finally, Appellate counsel advised Appellant of his right to

object to this motion for withdrawal of counsel, enclosing then

forwarding a copy of said motion December 29, 2015 by U.S.

First Class Mail and Certified Mail, Return Receipt Requested

#7014 2120 0003 3959 1292 to Appellant’s last known address:

10091 Stonybrook Circle, Apt. A

Indianapolis, Indiana 46229

(317) 912-5762.

WHEREFORE, PREMISES CONSIDERED, Donald M. Crane prays

that the Court enter an order discharging him as Appellate Counsel for R.A.C.,

Sr. aka R.C.

Respectfully submitted, 810 South Mason Road, Suite 350 Katy, Texas 77450 Telephone (281) 392-6611 Facsimile (281) 392-5383 State Bar No. 05005900 donmcrane@gmail.com ATTORNEY AD LITEM ON APPEAL FOR APPELLANT R.A.C., SR., aka R.C.

CERTIFICATE OF CONFERENCE This motion is unopposed.

CERTIFICATE OF SERVICE I hereby certify that on this 29 th day of December, 2015, a true

and correct copy of the foregoing Unopposed Motion for Withdrawal of

Counsel was served in accordance with the TRAP.

1. Sandra D. Hachem

Senior Assistant County Attorney

1019 Congress Avenue, 16 th Floor

Houston, Texas 77002-1700

(713) 437-4700 fax

2. Sylvia Yvonne Escobedo

917 Franklin, Suite 100

Houston, Texas 77002-1930

(713) 655-0200 fax