ACCEPTED
03-15-00227-CR
6697411
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/28/2015 11:18:15 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00227-CR
PEDRO PEREZ MORALES, ) COURT OF APPEALS, FILED
THIRD IN
3rd COURT OF APPEALS
Appellant ) AUSTIN, TEXAS
) 8/28/2015 11:18:15 AM
VS. ) SUPREME JUDICIAL DISTRICT
JEFFREY D. KYLE
Clerk
)
THE STATE OF TEXAS, )
Appellee ) AUSTIN, TEXAS
MOTION TO WITHDRAW AS COUNSEL
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW KIRK HAWKINS, attorney of record for PEDRO PEREZ
MORALES, and respectfully requests that he be allowed to withdraw as counsel for
Appellant, and for cause would show the Court the following:
I.
The undersigned attorney was unable to find any reversible error and filed a
frivolous appellate brief on behalf of Appellant. The undersigned attorney respectfully
requests that he be allowed to withdraw as attorney of record for Appellant.
II.
Appellant’s current address is TDCJ# 01987931, Wheeler State Jail, 986 County
Road AA, Plainview, Texas 79072. Appellant has been delivered a copy of this
motion by mailing same to Appellant at his current address.
III.
Appellant has been notified in writing of his right to file his own brief and to
review the record in this case.
WHEREFORE, PREMISES CONSIDERED, the undersigned attorney prays
the Court grant this motion and allow him to withdraw as counsel of record for
Appellant PEDRO PEREZ MORALES.
Respectfully submitted,
___/s/ Kirk Hawkins_________________
KIRK HAWKINS
P.O. BOX 3645
SAN ANGELO, TEXAS 76902
325/658-5585
STATE BAR NO. 09250400
E-Mail: kirkhawkinslaw@gmail.com
CERTIFICATE OF CONFERENCE
I certify that on the 28th day of August, 2015, I spoke by telephone with Mr.
Jason Ferguson, Assistant District Attorney, who stated he had no objection to this
Motion to Withdraw.
____/s/ Kirk Hawkins__________________
Kirk Hawkins
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above was served on Mr. Jason
Ferguson, Assistant District Attorney, Tom Green County Courthouse, Court Street
Annex, 124 West Beauregard, San Angelo, Texas 76903; and on Appellant, Mr. Pedro
Perez Morales #01987931, Wheeler State Jail, 986 County Road AA, Plainview, Texas
79072, on this 28th day of August, 2015.
____/s/ Kirk Hawkins__________________
Kirk Hawkins