Pedro P. Morales v. State

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