Opinion
10-23-00231-CR
04-08-2024
LUCKUS BAINES MOORE, Appellant, v. THE STATE OF TEXAS Appellee.
Anthony Smith State Bar No. 00788793 Attorney for Appellant
Anthony Smith State Bar No. 00788793 Attorney for Appellant
MOTION TO WITHDRAW AS ATTORNEY OF RECORD
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Anthony Smith, attorney of record in the above cause, and makes this his Motion to Withdraw as Counsel in the above-styled and numbered causes, and for cause would show as follows:
I.
Withdrawal can be accomplished without material adverse effect on the interests of the client and without unnecessarily delaying the due administration of justice.
II.
The Appellant has failed to substantially fulfill an obligation to counsel regarding the lawyer's services, including payment of legal fees. Appellant has been given reasonable warning that the lawyer will withdraw unless payment is made with the attorney. Continued representation of the Appellant by Counsel will result in an unreasonable financial burden on the lawyer and has been rendered unreasonably difficult by the client. (Tex.Disp.R.Prof.Conduct. 1.15(b)(5)(6).
III.
Continued representation of the Appellant by counsel will result in prejudice to the Appellant in that he will not receive effective assistance of counsel and/or a fair appeal in this case for the reasons stated above. Appellant herein request a court-appointed attorney. IV. A copy of this Motion has been mailed to Defendant at his last known address:
LUCKUS BAINES MOORE TDCJ NO.: 02457517 LEGAL MAIL BETO UNIT 1391 FM 3328 TENNESSEE COLONY, TEXAS 75880
WHEREFORE, PREMISES CONSIDERED, Anthony Smith, Movant, respectfully requests that the Court grant his motion and withdraw his name as attorney of record in the above styled and numbered cause and appoint the Appellant an attorney.