ACCEPTED 01-15-00487-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 8/24/2015 3:29:17 PM CHRISTOPHER PRINE CLERK NO. 01-15-00487-CR IN THE COURT OF APPEALS FILED IN ) 1st COURT OF APPEALS HOUSTON, TEXAS FIRST DISTRICT 8/24/2015 3:29:17 PM CHRISTOPHER A. PRINE HOUSTON, TEXAS Clerk

NO. 1416994 IN THE TRIAL COURT 230TH JUDICIAL DISTRICT HARRIS COUNTY, TEXAS

FREDIS MAURICIO FLORES § APPELLANT vs. § THE STATE OF TEXAS § APPELLEE

MOTION TO SUBSTITUTE COUNSEL ON APPEAL

ALLEN C. ISBELL 2016 Main St., Suite 110 Houston, Texas 77002 (713) 236-1000 Fax No. (713) 236-1809 STATE BAR NO. 10431500 email: [email protected] COUNSEL ON APPEAL TO THE HONORABLE COURT OF APPEALS: COMES NOW ALLEN C. ISBELL and respectfully requests this Honorable Court grant his motion to substitute as counsel on appeal for appellant, FREDIS MAURICIO FLORES. For cause, appellant would show the Court as follows: I.

On May 14, 2015, appellant was convicted of the offense of Driving While Intoxicated (3rd Offender), in Cause No. 1416994, in the 230th District Court of Harris County, Texas entitled The State of Texas vs. Fredis Mauricio Flores. The trial court appointed Attorney J. Celeste Carter Blackburn to represent appellant on appeal.

II .

On August 24, 2015, ALLEN C. ISBELL was retained to represent appellant on appeal. Appointed Counsel consents to the substitution of ALLEN C. ISBELL as counsel on appeal for Fredis Mauricio Flores.

II I.

This motion is urged at the first opportunity and is not sought for purposes of delay but so that justice may be served.

c:\appeals\flores\mtn . to substitute counsel on appeal 2 WHEREFORE, PREMISES CONSIDERED, appellant prays that this Honorable Court grant this motion to substitute counsel on appeal and substitute ALLEN C. ISBELL as appellate counsel for Fredis Mauricio Flores on appeal.

Respectfully submitted, Isl Allen C. Isbell ALLEN C. ISBELL 2016 Main St. , Suite 110 Hou~on , Texas77002 (713) 236-1000 Fax No. (713) 236-1809 STATE BAR NO. 10431500 email: [email protected] COUNSEL ON APPEAL

AGREED AND APPROVED:

7'9.cEQt/~R~~µ Attorney at Law N. Rivershire Dr. , Suite 285 Conroe, Texas 77304 (936) 703-5000 Fax No. (877) 900-2822 ST~T~ BAR NO. 24038803 ~ 8-i'~ <f>1 ~ht-.~;-t/r>- c:\appeals\flores\mtn . to substitute counsel on appeal 3 Certificate of Service I hereby certify that on this 24th day of August, 2015, a true and correct copy of the foregoing Motion for Substitution of Counsel on Appeal has been sent to the District Attorney's Office, Appellate Division, and to Mr. Fredis Mauricio Flores, appellant.

Isl Allen C. Isbell ALLEN C. ISBELL

Certificate of Compliance The undersigned attorney on appeal certifies this motion is computer generated and consists of 418 words. Counsel is relying on the word count provided by the Word Perfect computer software used to prepare the motion.

Isl Allen C. Isbell ALLEN C. ISBELL

c:\appeals\flores\mtn . to substitute counsel on appeal 4