Edward Rudolph Turnbull, IV v. Commission for Lawyer Discipline, Daniela Grosz, Daniel Martinez, Seana Willing, John S. Brannon, Amanda Kates, Jenny Hodgkins, and the Board of Directors of the State Bar of Texas, Cindy v. Tisdale, Steve Benesh, Laura Gibson, Kennon Lily Wooten

ACCEPTED 15-24-00095-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/12/2025 4:16 AM Court of Appeals Number: 15-24-00095-CV CHRISTOPHER A. PRINE CLERK RECEIVED IN Trial Court Case Number: D-1-GN-24-002025 15th COURT OF APPEALS AUSTIN, TEXAS 2/12/2025 4:16:05 AM CHRISTOPHER A. PRINE Clerk Edward Rudolph Turnbull, IV v. IN THE COURT OF APPEALS Commission for Lawyer Discipline, Daniela Grosz, Daniel Martinez, Seana FIFTEENTH DISTRICT Willing, John S. Brannon, Amanda Kates, Jenny Hodgkins, and the Board AT AUSTIN, TEXAS of Directors of the State Bar of Texas, Cindy V. Tisdale, Steve Benesh, Laura Gibson, Kennon Lily Wooten, et al.

Letter addressed to the Clerk of the COA 15th District of Texas at Austin

AMICUS CURIAE CITIZEN’S STATEMENT In compliance with the Texas Rules Appellate Procedure (TRAP) Rule 11 (c); Amicus Curiae Citizen states that he did not receive any fee paid or to be paid for preparing the amicus curiae letter brief and submitted on 02/12/2025, via electronic filing EFILETX system in the case number assigned: 15-24-00095-CV and filed at the Court of Appeals 15th District of Texas at Austin.

According to Texas Secretary of State, General Counsel Office, the (03) three currently officers of holding a public office in the State Bar of Texas at Board of Officers and Directors; they have not filed with the Texas Secretary of State their Statement Officer Forms (Anti-Bribery Statement Forms) and the Sworn Oath of Office Affidavit Forms as required by the Texas Constitution, Article XVI, Section 1 and to take an office legitimately as Office Holders in Texas and for this reason they are liable to be removed immediately of the public office in the State Bar of Texas via a Petition for Quo Warranto and under the provisions of the Civil Practice and Remedies Code (CPRC), Title 3, Extraordinary Remedies, Chapter 66.

Sec. 66.001: GROUNDS. An action in the nature of quo warranto is available if: (1) A person usurps, intrudes into, or unlawfully holds or executes a franchise or an office, including an office in a corporation created by the authority of this state; (2) A public officer does an act or allows an act that by law causes a forfeiture of his office; (3) An association of persons acts as a corporation without being legally incorporated; (4) A corporation does or omits an act that requires a surrender or causes a forfeiture of its rights and privileges as a corporation; (5) A corporation exercises power not granted by law… Sec. 66.002: INITIATION OF SUIT. (a) If grounds for the remedy exist, the attorney general or the county or district attorney of the proper county may petition the district court of the proper county or a district judge if the court is in vacation for leave to file an information in the nature of quo warranto. (b) The petition must state that the information is sought in the name of the State of Texas. (c) The attorney general or county or district attorney may file the petition on his own motion or at the request of an individual relator. (d) If there is probable ground for the proceeding, the judge shall grant leave to file the information, order the information to be filed, and order process to be issued.

Sec. 66.003: JUDGMENT. If the person against whom the information is filed is found guilty as charged, the court: (1) Shall enter judgment removing the person from the office or franchise; (2) Shall enter judgment for the costs of prosecution in favor of the relator; and (3) May fine the person for usurping, intruding into, or unlawfully holding and executing the office or franchise.

As an American Law Principle, no one is above the law.

Dated: February 12, 2025 Respectfully submitted,

/s/Adriano Kruel Budri Adriano Kruel Budri Amici Curiae Citizen Email address: [email protected]

CERTIFICATE OF SERVICE I certify that I served all parties to this appeal through the Court’s electronic filing system, including Appellant’s and Appellee’s counsel on 02/12/2025.

/s/Adriano Kruel Budri Adriano Kruel Budri Amici Curiae Citizen Email address: [email protected]

Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Envelope ID: 97268804 Filing Code Description: Letter Filing Description: Letter addressed to the Clerk of the COA 15th District of Texas at Austin Status as of 2/12/2025 7:18 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Pat Mizell [email protected] 2/12/2025 4:16:05 AM SENT Billy SHart [email protected] 2/12/2025 4:16:05 AM SENT Jay Rudinger [email protected] 2/12/2025 4:16:05 AM SENT David Kitner 11541500 [email protected] 2/12/2025 4:16:05 AM SENT Jadd Masso 24041411 [email protected] 2/12/2025 4:16:05 AM SENT Royce Lemoine 24026421 [email protected] 2/12/2025 4:16:05 AM SENT Richard Huntpalmer 24097857 [email protected] 2/12/2025 4:16:05 AM SENT Gaines West 21197500 [email protected] 2/12/2025 4:16:05 AM SENT John Rudinger 24067852 [email protected] 2/12/2025 4:16:05 AM SENT Judd Stone 24076720 [email protected] 2/12/2025 4:16:05 AM SENT Daniel Olds 24088152 [email protected] 2/12/2025 4:16:05 AM SENT Brooke Noble [email protected] 2/12/2025 4:16:05 AM SENT Michael Graham 24113581 [email protected] 2/12/2025 4:16:05 AM SENT Emily Bamesberger [email protected] 2/12/2025 4:16:05 AM SENT Justin B.Cox [email protected] 2/12/2025 4:16:05 AM SENT Gaines West [email protected] 2/12/2025 4:16:05 AM SENT