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IN THE COURT OF APPEALS FOR THE 

FIRST DISTRICT OF TEXAS AT HOUSTON 

NO. 01-15-00547-CR

NO. 01-15-00548-CR

NO. 01-15-00549-CR

WILLIE CLARKE 

Appellant, 

On Appeal From the 178th

District Court of Harris County 

V. Trial Cause Nos 1453864, 

1457279 & 1465671 

THE STATE OF TEXAS 

Appellee 

MOTION TO WITHDRAW 

TO THE HONORABLE JUDGES OF SAID COURT: 

 COMES NOW, counsel for WILLIE CLARKE Appellant in the above cause, 

would respectfully request the Court to grant her motion to withdraw. In support of 

said motion, counsel would show unto the Court the following: 

I.

This appeal lies from Appellant's convictions in The State of Texas v. Willie Clarke 

Cause Numbers 1453864, 1457279 & 1465671 in the 178th District Court of Harris 

County. Appellant was found guilty of theft third offender, and two cases of 

fraudulent use of identifying information. Appellant was sentenced to six months 

confinement in the State Jail on the theft case and one of the fraudulent use of 

identifying information. He was sentenced to three years in the Institutional Division 

ACCEPTED

01-15-00548-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

9/4/2015 1:14:33 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 9/4/2015 1:14:33 PM CHRISTOPHER A. PRINE Clerk
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of the Texas Department of Criminal Justice on the second case of fraudulent use of 

identifying information. Notice of Appeal was timely filed. On September 4, 2015, 

counsel filed an Anders brief.

II.

Appellant is indigent, a judicial finding having been made on February 9, 2015. 

The Harris County Public Defender’s Office was appointed to represent Appellant on 

appeal. Counsel believes the appeal to be wholly frivolous, and files this her motion to 

withdraw. The supporting brief filed simultaneously with this motion to withdraw

shows good cause for the granting of this motion to withdraw.

III.

Pursuant to Kelly v. State, 436 S.W.3d 313 (Tex. Crim. App. 2014), the 

undersigned is providing copies of the following items to Appellant:

1. the Anders brief filed 

2. the Motion to Withdraw

3. the clerk’s record consisting of 1 volume in all three cause numbers

4. the extension of time for pro se brief

5. a form pro se motion for access to the appellate record

Counsel has also advised Appellant that he has the right to file a pro se response to 

the Anders brief and has the right to request this Court provide him access to the 

record and the right to review the record prior to filing a response. Counsel has also 
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advised Appellant should this Court agree that the appeal is frivolous, he has the right 

to file a pro se Petition for Discretionary Review with the Court of Criminal Appeals. 

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this 

Honorable Court grants this Motion to Withdraw.

Respectfully submitted,

Alexander Bunin

Chief Public Defender

/s Angela Cameron

Angela Cameron

State Bar No. 00788672

Harris County Public Defender’s Office

Assistant Public Defender

1201 Franklin 13th Floor 

Houston, Texas 77002

Tel: 713-368-0016

CERTIFICATE OF SERVICE

I certify that on the 4th day of September 2015 a copy of the foregoing 

instrument has been served upon the State of Texas via electronic service. 

/s Angela Cameron

ANGELA CAMERON