ACCEPTED
12-15-00111-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
8/24/2015 6:11:12 PM
CATHY LUSK
CLERK
12-15-00111-CR
CHARLIE MOTES § IN THE COURT OF APPEALS
§
vs. § FILED IN
12th JUDICIAL DISTRICT
12th COURT OF APPEALS
§ TYLER, TEXAS
STATE OF TEXAS § TYLER, TEXAS
8/24/2015 6:11:12 PM
CATHY S. LUSK
MOTION TO WITHDRAW Clerk
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes James Huggler, Counsel for the Appellant, in the above styled and numbered
causes, and would show the Court as follows:
I. Factual and Procedural Background
Counsel was appointed to serve as appellate counsel in these matters on April24, 2015. The
Brief of the Appellant is due on August 24,2015.
II. Grounds for Withdrawal
Counsel has reviewed the Clerk's Record and the Court Reporter's Record in these cases.
Following a professional evaluation of the record, it is Counsel's opinion that there is no valid issue
to present to this Court, and that the record contains no reversible error or jurisdictional defects.
Counsel has filed an Appellant's Briefin accordance with Anders v. California, 386 U.S. 738 (1967).
Finding no valid issue to present to the Court, Counsel seeks to withdraw.
Counsel has sent Appellant explaining his rights, and the ability to pursue his own appeal,
and a motion to obtain the record if he desires to do so in this matter, and attaches a copy of that
letter as Exhibit A to this Motion.
Page 1 of 4
III. Prayer for Relief
Counsel requests that he be allowed to withdraw, and for other such relief as the Court may
deem appropriate.
Respectfully submitted,
Law Office of James W. Huggler, Jr.
100 E. Ferguson, Suite 805
Tyler, Texas 75702
Tel: (903) 593-2400
Fax: (903) 593-3830
By: IS/ James W. Huggler. Jr.
James Huggler
State Bar No. 00795437
Attorney for Appellant
Page 2 of 4
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Motion has been delivered to Michael
West, Counsel for the State, and the Appellant, Charlie Motes, at the addresses listed below
on this the 24th day of August, 2015 by hand delivery or regular mail or the State of Texas
electronic filing system. Counsel also certified that he has provided Charlie Motes, a motion
to obtain the record if he so chooses.
lSI James W. Huggler. Jr.
James Huggler
Michael West Charlie Motes
Smith County District Attorney's Office 489 West Ayers
100 North Broadway, 4th Floor Frankston, Texas 75763
Tyler, Texas 75702
Page 3 of 4
Exhibit A
Letter to Charlie Motes
Page4of 4
Board Certified in Criminal Law ATIORNEY AT LAW
Board Certified in Criminal Appellate Law Texas Board of Legal Specialization
August 24, 2015
Charlie Motes
489 West Ayers
Frankston, Texas 75763
RE: Charlie Motes v. State
Appeal Number: 12-15-00111-CR
Trial Number: 114-1777-13
Dear Mr. Motes,
I am sending you a copy of the Appellant's Brief and a Motion to Withdraw that I have filed with
the Twelfth Court of Appeals in this matter. I have thoroughly reviewed the record, and have found
no reversible error or jurisdictional defect in these cases. However, you may choose to file a Brief
of your own in these matters. I am also sending you a motion to obtain access to the record for your
use. If you desire to file your own brief in the case, please sign the motion to allow access to the
record, and return it to me immediately and I will make the necessary copies and file the document
for you. If you have any questions, please feel free to contact me.
Enclosures: Appellant's Brief
Motion to Withdraw
Appellant's Motion to Obtain Record
C:\data\Corcl User Filca\Ciients\APPEALS\Motes, Ch111lie Joseph\Ciient.Brief.wpd
First Place Building • 100 East Ferguson, Suite 805 • Tyler,Texas 75702
903-593-2400 • www.jameshugglerlaw.com • Fax 903-593-3830