PD-0758-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 9/24/2015 3:39:52 PM
Accepted 9/24/2015 4:29:17 PM
IN THE COURT OF CRIMINAL APPEALS OF TEXAS ABEL ACOSTA
CLERK
DEWAN DONELL MORGAN, §
APPELLEE, §
§
vs. § N0. PD-0758-15
§
THE STATE OF TEXAS, §
APPELLANT. § September 25, 2015
APPELLEE’S MOTION TO WITHDRAW
AND SUBSTITUTE APPOINTED COUNSEL
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
NOW COMES, J. Stanley Goodwin, Attorney for Appellee, Dewan Donell
Morgan, and respectfiilly files this Motion to Withdraw and Substitute Appointed
Counsel, and in support thereof shows:
I.
J. Stanley Goodwin was appointed by the trial court as Attorney for Defendant
on appeal.
II.
The Court of Appeals for the Second District of Texas in Fort Worth reversed
Defendant’s burglary conviction and entered a judgment convicting Defendant of a
lesser included offense of assault.
APPELLEE’S MOTION TO WITHDRAW AND SUBSTITUTE APPOINTED COUNSEL ~ Page 1
IH.
The Court of Criminal Appeals of Texas granted the State’s Petition for
Discretionary Review on September 16, 2015.
IV.
J. Stanley Goodwin filed a Motion to Substitute Appointed Counsel (see
attached, Exhibit A). The trial court appointed Christopher Abel to represent
Defendant in this matter.
V.
Christopher Abel’s address is: 2609 Sagebrush Drive, Suite 202, Flower
Mound, Texas 75028; phone number: 972.584.7837; facsimile: 972.947.3813;
email: chris@flowermoundcriminaldefense.com; Texas Bar No.2 240435 16.
WHEREFORE, PREMISES CONSIDERED, the Appellee respectfully
requests that the Court permit J. Stanley Goodwin to withdraw as attorney of record
and allow Christopher Abel to substitute in as attorney for Appellee.
APPELLEE’S MOTION TO WITI-[DRAW AND SUBSTITUTE APPODITED COUNSEL - Page 2
Respectfully submitted,
~
~~ 08178958
Goodwin
ey
303 North Carroll, Suite 234
Denton, Texas 76201
940.382.8181
stang0512@gmail.com
Acknowledging receipt of appointment,
C1'h'i§opherVAbel
TBN 24043516
/X
2609 Sagebrush Drive, Suite 202
\
Flower Mound, Texas 75028
972.584.7837
972.947.3813 (facsimile)
chris@flowermoundcriminaldefense.com
APPELLEE’S MOTION TO WITI-IDRAW AND SUBSTITUTE APPOINTED COUNSEL - Page 3
CERTIFICATE OF SERVICE
A copy of the Appe1lee’s Motion to Withdraw and Substitute Appointed
Counsel was hand delivered to Christopher Abel at 2609 Sagebrush Drive, Suite
202, Flower Mound, Texas 75028, and also hand delivered to the Denton County
District Attorney’s Office on this the day of September, 2015.
J.
file? Goodwin
APPELLEE’S MOTION TO WITHDRAW AND SUBSTITUTE APPOINTED COUNSEL - Page 4
EXHIBIT A
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II
F L ED
III
N0. F-2013-1704-D |
ZUISSEP I8 PH 2% I71
STATE OF TEXAS
vs. 351"” JUDI RICT
DEWAN DONELL MORGAN DENTON COUNTY, TEXAS
MOTION TO SUBSTITUTE APPOINTED COUNSEL
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes J STANLEY GOODWIN,
.
Attorney for the Defendant, DEWAN
DONELL MORGAN, and respectfiilly files this Motion to Substitute appointed counsel
and in support thereof shows:
I.
J . Stanley Goodwin was appointed by the court as Defendant’s attorney on
appeal.
II.
On May 28, 2015 the Court of Appeals for the Second District of Texas in Fortwoith
reversed defendant’s burglary conviction and entered judgment convicting defendant of
the lesser included offense of assault.
III.
On September 16, 2015, the Court of Criminal Appeals granted the State’s
Petition for Discretionary Review‘
IV.
Because of other commitments, undersigned counsel will not have adequate time
time to devote to the writing of the defendant’s brief and oral argument in the instantcase.
V.
The defendant has agreed to this motion as is shown by his signature below.
WFIEREFORE, PREMISES CONSIDERED, Attorney for the defendant prays that
the Court grant this motion and appoint another attorney to represent the defendant
herein.
AGREED: Respectfillly submitted,
ad
DEFEND
03 N. Carroll, Suite 234
Denton, TX 76201
940-382-8181
stang0512@gmail.com
State Bar No. 08178985
Attorney for the Defendant
CERTIFICATE OF SERVICE
This is to certify that on September 18, 2015, a true and correct copy of the above
and foregoing document was personally served on the Denton County District
Attomey’s Office and on the defendant, Dewan Morgan.
’
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FILED
N0. F-2013-1704-D
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STATE on TEXAS
vs. 362"” JUDICIAL msrmcr
DEWAN DONELL MORGAN DENTON COUNTY, TEXAS
ORDER
CAME ON for hearing on the [
9 day of September 2015, and the Court being
of the opinion that same should
IT IS THEREFORE ORDERED that J. Stanley Goodwin be and is hereby allowed
to withdraw as Attorney for the Defendant.
IT IS FURTHER ORDERED that art ‘é g £ Q, / , a duly licensed
attorney in the State of Texas be and is hereby appointed to represent the defendant.
T’
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