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 2/10/2025 12:00 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 2/10/2025 12:00:00 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

Even the Office of the District Attorney of Travis County has declined to file suit for injunctive relief under the Public Information Act (“PIA”) as state statute in Texas and against the State Bar of Texas, and to enforce to provide public information requested by the Requester as Citizen under the Public Information Act (“PIA”).

According to the Office of the District Attorney of Travis County and in charge for Public Integrity Unit in the Team Lead, Mr. Rob Drummond has written a response letter dated on 09/12/2022 and addressed to Adriano K. Budri, as Requester and Citizen that the Office of the District Attorney of Travis County for Public Integrity Unit has declined to file suit for injunctive relief pursuant to Texas

Government Code Chapter 552.3215, and alleging that such request for injunctive relief, it does not apply to the state agencies of the judiciary branch of the state government in the State of Texas and because the Texas Government Code Chapter 552; it applies to a “State Agency” which is “in the executive branch” only and not from the State Bar of Texas as State Administrative Agency and from the Judicial Department of the state government in the State of Texas and under the Texas Government Code Chapter 552.3215.

However, the Texas Government Code, Title 2, Judicial Branch, Subtitle G, Attorneys, Chapter 81, as state statute “State Bar Act”, Subchapter B, Administrative Provisions, Section 81.011, General Powers, (a) The state bar is a public corporation and an administrative agency of the judicial department of government. See: Section: 81.011(a), but the State Bar of Texas as State Administrative Agency of the Judicial Department of the state government in the State of Texas is covered under the Texas Government Code Chapter 552 for Public Information Requirements as a “State Agency” and being part of the Judicial Branch of the state government of the State of Texas and for Open Records requirements. See: Section 81.033 for Open Records, (a) it describes that all records of the state bar, except for records pertaining to grievances that are confidential under the Texas Rules of Disciplinary Procedure, and records pertaining to the Texas Board of Legal Specialization are subject to Chapter 552 of the Public Information Requirements and codified by the Texas Government Code for Texas Public Information Act (“PIA”). Added by Acts 1987, 70th Leg., Ch. 148, Section: 3.01, eff. Sept. 1, 1987. Amended by Acts 1991, 72nd Leg., Ch. 795, Sec. 15, eff. Sept. 1, 1991; Acts 1995, 74th Leg., Ch. 76, Sec. 5.95(93), eff. Sept. 1, 1995 (State Statute “State Bar Act”, Texas Government Code, Section 81.011).

See: Copy of the letter issued on 09/12/2022 and electronically signed by Rob Drumond (Document Signed DF8C9022FE75434 via DocuSign) as part of the Team Lead of the Public Integrity Unit of the Office of the District Attorney in Travis County at P. O. Box 1748, Austin, TX 78767, Telephone: (512) 854-95400, Telefax: (512) 854-4206, Jose P. Garza as District Attorney and Trudy Strassburger, First Assistant and registered as DocuSign Envelope ID: 1EDD1429- F78B-40F8-8378-9BA23EEA18A0 and with physical address located at Ronald Earle Building, 416 W. 11th Street, Austin, Texas 78701. The letter issued, signed and mailed via USPS first class mail in Certified Mail Number has been with tracking number 70183090000204788393, and having been posted on 09/14/2022 in Austin, Travis County, Texas.

The state statute “State Bar Act” requires that the Chief Disciplinary Counsel MUST provide the full explanation for dismissal of the grievance inquiries and grievance complaints to Complainant.

This court can issues an order and demanding that the lower court must adjudicate the merits of this civil lawsuit about the Appellant/Plaintiff requesting an injunctive relief and pursuant the Texas Government Code Section 81.033 for Open Records, (a) and that it describes that all records of the state bar, except for records pertaining to grievances that are confidential under the Texas Rules of Disciplinary Procedure, and records pertaining to the Texas Board of Legal Specialization are subject to Chapter 552 of the Public Information Requirements and codified by the Texas Government Code for Texas Public Information Act (“PIA”).

The Chief Disciplinary Counsel (“CDC”) of the State Bar of Texas’ Dismissal Notice Letter is not a confidential matter under the Texas Rules of Disciplinary Procedure and the state statute “State Bar Act” requires release of the full explanation to the Complainant about the dismissal notice letters from grievance inquiries and grievance complaints.

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 02/07/2025, 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.

Dated: February 7, 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 02/07/2025.

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

EXHIBIT A

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: 97147695 Filing Code Description: Letter Filing Description: Letter addressed to the Clerk of the COA 15th District of Texas at Austin Status as of 2/10/2025 7:08 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Pat Mizell [email protected] 2/8/2025 12:17:14 AM SENT Billy SHart [email protected] 2/8/2025 12:17:14 AM SENT Jay Rudinger [email protected] 2/8/2025 12:17:14 AM SENT David Kitner 11541500 [email protected] 2/8/2025 12:17:14 AM SENT Jadd Masso 24041411 [email protected] 2/8/2025 12:17:14 AM SENT Royce Lemoine 24026421 [email protected] 2/8/2025 12:17:14 AM SENT Richard Huntpalmer 24097857 [email protected] 2/8/2025 12:17:14 AM SENT Gaines West 21197500 [email protected] 2/8/2025 12:17:14 AM SENT John Rudinger 24067852 [email protected] 2/8/2025 12:17:14 AM SENT Judd Stone 24076720 [email protected] 2/8/2025 12:17:14 AM SENT Daniel Olds 24088152 [email protected] 2/8/2025 12:17:14 AM SENT Brooke Noble [email protected] 2/8/2025 12:17:14 AM SENT Michael Graham 24113581 [email protected] 2/8/2025 12:17:14 AM SENT Emily Bamesberger [email protected] 2/8/2025 12:17:14 AM SENT Justin B.Cox [email protected] 2/8/2025 12:17:14 AM SENT Gaines West [email protected] 2/8/2025 12:17:14 AM SENT