Opinion

Jared P. Raia, Individually and as Trustee for the Dennis Raia 2012 Family Trust v. Keith Crockett

Court
Texas Court of Appeals, 3rd District (Austin)
Filed
Sep 26, 2016
Status
Published
Cited by
0 cases

The opinion

ACCEPTED

03-16-00562-CV

12897832

THIRD COURT OF APPEALS

AUSTIN, TEXAS

9/26/2016 12:36:34 PM

JEFFREY D. KYLE

CLERK

No. 03-16-00562-CV

FILED IN

3rd COURT OF APPEALS

In the Third Court of Appeals AUSTIN, TEXAS

9/26/2016 12:36:34 PM

Austin, Texas JEFFREY D. KYLE

Clerk

JARED P. RAIA, INDIVIDUALLY AND AS TRUSTEE FOR

THE DENNIS RAIA 2012 FAMILY TRUST

Appellants

v.

KEITH CROCKETT

Appellee

APPEAL FROM CAUSE NO. D-1-GN-15-001066

3523RD JUDICIAL DISTRICT COURT OF TRAVIS COUNTY, TEXAS

HON. STEPHEN YELENOSKY, PRESIDING

APPELLANTS’ MOTION TO SUBSTITUTE COUNSEL

TO THE HONORABLE THIRD COURT OF APPEALS:

Appellants Jared P. Raia, Individually and as Trustee for the Dennis Raia 2012

Family Trust, file this motion to substitute counsel in accordance with Texas Rules

of Appellate Procedure and 10.1. In support of this motion, Appellants respectfully

show the following:

1

1. Appellants have retained D. Todd Smith and Maitreya Tomlinson

to represent them in this cause and request that all future notices, orders and

opinions be sent to D. Todd Smith and Maitreya Tomlinson at the following address:

D. Todd Smith

State Bar No. 00797451

Maitreya Tomlinson

State Bar No. 24070751

SMITH LAW GROUP LLLP

1250 Capital of Texas Highway South

Three Cielo Center, Suite 601

Austin, Texas 78746

(512) 439-3230

(512) 439-3232 (fax)

todd@appealsplus.com

maitreya@appealsplus.com

2. Accordingly, John G. Lione, Jr., Laura Sanders Fowler, and The

Fowler Law Firm, PC respectfully request to be withdrawn, and that D. Todd

Smith and Maitreya Tomlinson be substituted in as counsel of record for Appellants.

CONCLUSION AND PRAYER

For these reasons, Appellants respectfully request that the Court grant this

motion and substitute new counsel for Appellants. Appellants request all other

appropriate relief to which they are entitled.

2

Respectfully submitted,

SMITH LAW GROUP LLLP

By: Isl D. Todd Smith

D. Todd Smith

State Bar No. 00797451

todd@appealsplus.com

Maitreya Tomlinson

State Bar No. 24070751

maitreya@appealsplus.com

1250 Capital of Texas Highway South

Three Cielo Center, Suite 601

Austin, Texas 78746

(512) 439-3230

(512) 439-3232 (fax)

Counsel for Appellants

THE FOWLER LAW FIRM, P.C.

G. · ne, Jr. ,/

/

Sta-U:"Bar No. 1239,;l-SDO

jlione@thefowlerlawfirm.com

Laura S. Fowler

State Bar No. 08521200

lfowler@thefowlerlawfirm.com

312 W. University Avenue

Georgetown, Texas 78626

Previous Counsel for Appellants

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CERTIFICATE OF CONFERENCE

In compliance with Texas Rule of Appellate Procedure 10.1(a)(5), I certify

that on September 23, 2016, I conferred with Appellee’s lead counsel, Kim Brown,

about this motion. Mr. Brown informed me that Appellee does not oppose the relief

requested in this motion.

/s/ D. Todd Smith

D. Todd Smith

CERTIFICATE OF SERVICE

On September 26, 2016, in compliance with Texas Rule of Appellate

Procedure 9.5, I served this document by e-service and e-mail to:

Via e-Service: mailbox@brownlawyer.com

Via Facsimile: (512) 263-7454

Kim Brown

KIM D. BROWN ATTORNEY, PLLC

1310 Ranch Road 620 S., Suite B-203

Lakeway, Texas 78734

Counsel for Defendant

Via CMRRR: 70153010000085792028

Via First Class US Mail

Jared P. Raia

12400 W. Hwy. 71, Ste. 350-379

Austin, Texas 78738

/s/ D. Todd Smith

D. Todd Smith

4

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