01-14-00862-CR

In The Court Of Appeals Of Texas

For The 

First Supreme Judicial District Of Texas

______________________________________________________________ 

NO. 178th

IN THE 178th JUDICIAL DISTRICT COURT

OF HARRIS COUNTY, TEXAS

The Honorable David Mendoza, presiding

____________________________________________________________

ANDRE THOMPSON

Appellant

Vs.

THE STATE OF TEXAS

Appellee

____________________________________________________________

APPELLATE COUNSEL’S

MOTION TO WITHDRAW FROM FRIVOLOUS APPEAL 

____________________________________________________________

GLENN J. YOUNGBLOOD

Appellant's Attorney

5555 West Loop South Ste. 395

Bellaire, Texas 77401

(713)432-1013 [voice/FAX]

SBOT# 22217400

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/13/2015 7:29:20 PM CHRISTOPHER A. PRINE Clerk
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TO THE HONORABLE COURT:

Comes now Glenn J. Youngblood, Movant, asks the Court to permit him to 

withdraw as counsel on appeal pursuant to the authority of Tex.R.App.P., Rule 

6.5, Anders v. California, 386 US 738,744, 18 LEd.2d 493, 87 S Ct 1396 (1967); 

McCoy v Court of Appeals of Wisconsin, Dist. 1, 486 U.S. 429, 108 S.Ct. 1895, 

1902, 100 L.Ed. 2d 440 (1988); and would show unto the Honorable Court the 

following: .

1. On 10/8/2014 Movant was appointed by order of the Honorable, David 

Mendoza, Judge, 178th Judicial District Court, Harris County, Texas to 

represent the Appellant, Andre Thompson in his appeal in this cause.

2. After a conscientious review of the record in this case and the applicable 

law, Movant has concluded that the Appellant’s appeal in this matter lacks 

merit, has no reasonable expectation for reversal of the judgment and is,

therefore, frivolous.

3. Concurrent with the filing of this motion Movant has filed a Brief In Support 

Of Appellant Counsel’s Motion To Withdraw From Frivolous Appeal.

4. Movant has notified Appellant of the filing of this motion and of his right of 

access to the appellate record to file a pro se brief and the time period within 

which he must comply by letter and a copy of a Motion to Access the 

Appellate Record a copy of which is attached hereto as Exhibit “A” 
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WHEREFORE, PREMISES CONSIDERED, Movant prays the Honorable 

Court grant this motion to withdraw from representation of Appellant in the aboveentitled and numbered cause and that he be relieved of all further duties of 

representation of Appellant.

Respectfully submitted

___________________________ 

Glenn J. Youngblood

Attorney at Law

5555 West Loop South, Ste. 395

(713) 432-1013 [Voice/FAX]

SBOT# 22217400

glenlaw@comcast.net
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CERTIFICATE OF SERVICE

On the ________________ a true and correct copy of the foregoing 

Appellant Counsel’s Motion to Withdraw From Frivolous Appeal, including 

Exhibit A, attached thereto, and the Brief In Support Of Appellant Counsel’s 

Motion To Withdraw From Frivolous Appeal, were sent by U.S. Mail, Certified, 

Return Receipt Requested or via Electronic document transfer mailed as follows:

Name Address Cert.

Mail FAX

Hand 

Deliv

ered

Andre Thompson Appellant

TDC #01959294

Texas Department of 

Criminal Justice -

Institutional Division 

Holliday Unit

295 IH45 North,

Huntsvile, TX 77320

3

Harris County District 

Attorney’s Office,

Appellate Division

1201 Franklin

Houston, Texas 77002

FAX (713) 755-5809

Curry_alan@dao.hctx.net

3

________________________________ 

Glenn J. Youngblood