Bobby C. Johnson v. the Stte of Texas

ACCEPTED 06-16-00109-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/22/2016 7:31:11 PM DEBBIE AUTREY CLERK CAUSE NO. 06-16-00109-CR BOBBY C. JOHNSON IN THE SIXTH COURT OF APPEALS FILED IN V 6th COURT OF APPEALS THE STATE OF TEXAS TEXARKANA , TEXAS TEXARKANA, TEXAS 6/23/2016 8:06:00 AM DEBBIE AUTREY _____________________________________________________________________________ Clerk _____________________________________________________________________________ MOTION FOR APPOINTMENT OF APPELLATE ATTORNEY TO THE HONORABLE JUSTICES OF THE COURT: Now Comes William T. Hughey seeking the Appointment of an Appellate Attorney for Bobby C. Johnson in the pending case on appeal. In support of this motion counsel would tender to the Court the following: 1. Counsel on the 6th day of June 2016, filed electronically a Notice of Appeal for Appellant signed by the Appellant reflecting his desire for the appointment of an Appellate Attorney. 2.In connection with the filing the Notice of Appeal was filed with a letter to the Trial Court noticing Appellant’s need for the appointment of an Appellate Attorney. See Attachment A incorporated herein by reference. 3. The Notice of Appellant was processed and forwarded to this Honorable Court listing the undersigned as Appellate Counsel. 4.Said Notice of Appeal was filed to insure that Appellant Johnson appeal rights were protected but was not submitted for purposes of representing Appellant Johnson on Appeal. Wherefore Premise considered the undersigned Prays that upon review and consideration of this Motion that this Honor Court remands the pending Appeal to the Trial Court for appointment of Appellate Attorney for Appellant Bobby C. Johnson . Respectfully submitted, THE HUGHEY LAW FIRM PLLC BY: /s/ William T. Hughey WILLIAM T. HUGHEY SBC # 10245500 Hugheylaw@sbcglobal.net Ph. No. 903-935-5550 Fax No. 866-823-7185 P.O. Box 2012 Marshall, Texas, 75671 ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Motion has been delivered Via E-Serve to the Gregg County District Attorney Office on this 22st day of June 2016. /s/ William T. Hughey WILLIAM T. HUGHEY SBC # 10245500 Hugheylaw@sbcglobal.net Electronically Submitted 6/8/2016 10:06:46 AM Gregg County District Clerk By: Britnie Minor ,deputy The Hughey Law Firm P.L.L.C. June 6, 2016 Via E-File Hon. Judge David Brabham 188th District Court Gregg County, Texas Re: State of Texas vs. Bobby C. Johnson Cause Numbers 40,942-A Notice of Appeals Dear Judge Brabham I am filing contemporaneous with this letter Notice of Appeal for Mr. Bobby C. Johnson in the above referenced matters. I was originally retained in this matter by a family member of Mr. Johnson to represent Mr. Johnson in the disposition of the a Motion to Proceed with Adjudication which was heard and ruled on by this Court on May 23, 2016. I obtained a signed Notice of Appeals from Mr. Johnson on this date; the Notice of Appeal is being filed with this letter to protect Mr. Johnson appellate rights and as my final act of representation. The Notice of Appeal reflects Mr. Johnson indigent status and request for appointment of appellate counsel. I will await any additional directives of the Court to bring closure to my representation of Mr. Johnson. I Remain /s/ William T. Hughey William T. Hughey Re-filed 6-8-16 Original Filing Returned to Dark Cc: Gregg County ,District Attorney Office Via E-Serve THE HUGHEY LAW FIRM, P.L.L.C. P.O. Box 2012 Marshall, Texas, 75671 E-mail: Hugheylaw@sbcglobal.net Phone No. (903) 935-5550 Fax No. 1(866)-823-7185