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 appointedto serve as appellate counsel in these matters onApril24, 2015. The Briefofthe 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 ofthe record, it is Counsel's opinionthatthere isno valid issue to present to this Court, and that the record contains no reversible error orjurisdictional defects. Counselhasfiled anAppellant'sBriefinaccordancewithAndersv. California, 386U.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 ifhe desires to do so in this matter, and attaches a copy ofthat 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

### III. Prayer for Relief Counsel requests that he be allowed to withdraw, and for other such reliefas the Court may deem appropriate.
Respectfully submitted, Law Office ofJames 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

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### CERTIFICATE OF SERVICE This is to certify that a copy ofthe foregoing Motion has been delivered to Michael West, Counsel for the State, andtheAppellant, Charlie Motes, at the addresses listed below on this the 24th day ofAugust, 2015 by hand delivery orregular mail or the State ofTexas electronic filing system. Counsel also certifiedthathehasprovided CharlieMotes, a motion to obtain the record ifhe 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

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# Exhibit A
Letter to Charlie Motes

Page4of 4Board 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 ofLegal Specialization



### I am sending you a copy ofthe Appellant's Briefand a Motion to Withdraw that I have filed with the Twelfth Court ofAppeals inthis matter. Ihave thoroughly reviewedthe record, and have found no reversible error orjurisdictional defect in these cases. However, you may choose to file a Brief ofyourown in these matters. I am 

### also sending you amotion to obtain access to the record for your use. Ifyou desire to file your own briefin the case, please sign the motion to allow access to the record, and return it to me immediately and Iwill make the necessary copies and file the document for you. Ifyou 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