AETC II Privatized Housing, LLC v. Tom Green County Appraisal District ( 2015 )

ACCEPTED 03-13-00463-CV 8059721 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/2/2015 4:20:42 PM JEFFREY D. KYLE CLERK No. 03-13-00463-CV FILED IN 3rd COURT OF APPEALS In The Court Of Appeals AUSTIN, TEXAS For The Third Court Of Appeals District 12/2/2015 4:20:42 PM JEFFREY D. KYLE Austin, Texas Clerk AETC II PRIVATIZED HOUSING, LLC Appellant, V. TOM GREEN COUNTY APPRAISAL DISTRICT Appellee. ON APPEAL FROM THE 391ST DISTRICT COURT, TOM GREEN COUNTY, TEXAS TRIAL COURT CAUSE NO. D-10-0377-C APPELLANT'S MOTION FOR SUBSTITUTION OF COUNSEL BRUSNIAK LAW, PLLC Tracy Turner Texas Bar No. 24076743 tracy@txtax.com Three Galleria Tower 13155 Noel Road, Suite 1850 Dallas, Texas 75240 Telephone: (972) 250-6363 Facsimile: (972) 250-3599 Counsel for Appellants COMES NOW, AETC II PRIVATIZED HOUSING, LLC, Appellant in the above numbered and entitled cause, and pursuant to Rule 10 of the Texas Rules of Civil Procedure, respectfully asks the Court to substitute the law firm of Brusniak Law, PPLC and attorneys John Brusniak, Jr., Kory L. Ryan, and Tracy M. Turner as attorneys of record for the Appellant. John Brusniak, Jr., Kory L. Ryan, and Tracy M. Turner were previously representing the Appellant at Ryan Law Firm, LLP but have since left and formed Brusniak Law, PLLC. These are the same lawyers that were previously handling the lawsuit for Appellant, and will continue to represent the Appellant at Brusniak Law, PLLC. I. Pursuant to rule 10 of the Texas Rules of civil Procedure, Appellant's new attorney of record's information is as follows: John Brusniak, Jr. State Bar No. 03261500 john@txtax.com KoryL. Ryan State Bar No. 24068065 Kory@txtax.com Tracy M. Turner State Bar No. 24076743 tracy@txtax.com BRUSNIAKLAW, PLLC Three Galleria Tower 13155 Noel Rd., Suite 1850 Dallas, Texas 75240 Ph: (972) 250-6363 Fax: (972) 250-3599 II. Appellant approves of the substitution of the law firm ofBrusniak Law, PPLC in place and stead of the law firm of Ryan Law firm, LLP as its counsel of record. Motion for Substitution of Counsel--Page I III. This substitution is not sought for delay and will not be used as a basis for delaying the setting of this case. WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests the Court to enter an Order substituting the law firm ofBrusniak Law,.PLLC in place and stead of the law firm of Ryan Law Firm, LLP, as its counsel ofrecord in this matter and for such other and further relief to which it may be justly entitled. Respectfully submitted, BRUSNIAK LAW, PLLC Three Galleria Tower 13155 Noel Rd., Suite 1850 Dallas, Texas 75240 Ph: (972) 250-6363 Fax: (972) 250-3599 By: ls/TRACY M TURNER John Brusniak, Jr. State Bar No. 03261500 KoryL. Ryan State Bar No. 24068065 Tracy M. Turner State Bar No. 24076743 ATTORNEYS FOR APPELLANTS Motion for Substitution of Counsel--Page 2 Certificate of Conference On October 28, 2015, a conference was held with counsel for Appellee, concerning the merits of this motion. Counsel for Appellee is not opposed to this motion. On October 28, 2015, a conference was held with Ryan Law Firm, LLP, concerning the merits of this motion. Ryan Law Firm, LLP is not opposed to this motion. Isl Tracy M Turner Tracy M. Turner Certificate of Service I certify that a copy of the foregoing Motion for Substitution of Counsel was served on Defendant, Tom Green County Appraisal District, through counsel of record, James Robert Evans, Jr., Hargrove & Evans, LLP, 4425 Mopac South, Building 3, Suite 400, Austin, Texas 78735, jim@hellplaw.com, by electronic service through Efiletx.gov on December 2, 2015. Isl Tracy M Turner Tracy M. Turner Motion/or Substitution o/Cou11se/--Page 3