7/28/2019 Relators Motion to Refer Cause to Non-Resident Judge
D-1-GV-13-000511
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CAUSE NO. D-1-GV-13-000511
THE STATE OF TEXAS, IN THE 353RD JUDICIAL
Plaintiff
EX REL. RICHARD D. REED,
Relator v. DISTRICT COURT OF
ROSEMARY LEHMBERG,
Defendant,
In Her Official Capacity as District
Attorney of Travis County, Texas TRAVIS COUNTY, TEXAS
RELATORS MOTION TO REFER CAUSE TO PRESIDING JUDGE
FOR ASSIGNMENT TO A NON-RESIDENT JUDGE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Relator, Richard D. Reed, and, pursuant to the
provision of section
74.059(c)(4) of the Texas Government Code, hereby moves the
Court to request the presiding
judge of the Third Administrative Judicial Region of Texas to
assign another judge who is not a
resident of Travis County to hold a regular or special term of
court in Travis County to dispose
of the above-entitled-and-numbered cause. In support of such
motion, Relator would show unto
the Court as follows:
I. GROUNDS FOR MOTION
1. On May 29, 2013, Relator initiated a proceeding for the
removal of a local official under
section 87.015 of the Texas Local Government Code by filing an
original petition for removal in
the above-entitled-and-numbered cause seeking to remove
Defendant Rosemary Lehmberg from
the office of District Attorney of Travis County.
2. Section 74.059(c)(4) of the Texas Government Code provides
that a district court judge
shall, if an election contest or a suit for the removal of a
local official is filed in his court, request
Filed13 May 30 P2:38Amalia Rodriguez-MDistrict ClerkTravis
DistrictD-1-GV-13-000511
7/28/2019 Relators Motion to Refer Cause to Non-Resident Judge
D-1-GV-13-000511
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Relators Motion to Refer Cause to Presiding Judge for Assignment
to a Non-Resident Judge
Page 2
the presiding judge of the administrative region to assign
another judge who is not a resident of
the county to hold a regular or special term of court in that
county to dispose of the suit. TEX.
GOVT CODE, 74.059(c)(4).
II. PRAYER
WHEREFORE, PREMISES CONSIDERED, Relator respectfully moves the
Court to
request the Honorable Billy Ray Stubblefield, the presiding
judge of the Third Administrative
Judicial Region of Texas, to assign another judge who is not a
resident of Travis County to hold
a regular or special term of court in Travis County to dispose
of the above-entitled-and-
numbered cause.
Respectfully submitted,
______________________________
Richard D. Reed, Relator316 W. 12th Street, Suite 313
Austin, Texas 78701-1820
www.maverickcounsel.com
Telephone: 512-322-9443
Email: [email protected] Bar No. 16686100
CERTIFICATE OF SERVICE
I hereby certify that I have complied with Rule 21a of the Texas
Rules of Civil Procedureby serving a copy of the
above-and-foregoing Relators Motion to Refer Cause to Presiding
Judge
for Assignment to a Non-Resident Judge upon David A. Escamilla,
County Attorney of Travis
County, Texas, by delivering a copy of the said motion to an
employee at his office.
______________________________Richard D. Reed
