CHARLIE MOTES 

vs. 

STATE OF TEXAS 

12-15-00111-CR 

§ IN THE COURT OF APPEALS 

§ 

§ 12th JUDICIAL DISTRICT 

§ 

§ TYLER, TEXAS 

MOTION TO WITHDRAW 

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 

ACCEPTED

12-15-00111-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

8/24/2015 6:11:12 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 8/24/2015 6:11:12 PM CATHY S. LUSK Clerk
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. 

Michael West 

Smith County District Attorney's Office 

100 North Broadway, 4th Floor 

Tyler, Texas 75702 

lSI James W. Huggler. Jr. 

James Huggler 

Charlie Motes 

489 West Ayers 

Frankston, Texas 75763 

Page 3 of 4 
Exhibit A 

Letter to Charlie Motes 

Page4of 4 
Board Certified in Criminal Law 

Board Certified in Criminal Appellate Law 

August 24, 2015 

Charlie Motes 

489 West Ayers 

Frankston, Texas 75763 

RE: Charlie Motes v. State 

ATIORNEY AT LAW 

Appeal Number: 12-15-00111-CR 

Trial Number: 114-1777-13 

Dear Mr. Motes, 

Texas Board of Legal Specialization 

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