12-14-00309-CR 

STATE OF TEXAS 

§ IN THE COURT OF APPEALS 

I 12th JUDICIAL DISTRICT 

~ TYLER, TEXAS 

JOLLY NEELY 

VB. 

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 October 

27, 2014. The Brief of the Appellant is due on AprillO, 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 Brief in 

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

12-14-00309-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

4/10/2015 3:53:27 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 4/10/2015 3:53:27 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: /S/ 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, Jolly Neely, at the 

addresses listed below on this the lOth day of April, 2015 by hand delivery or 

regular mail or the State of Texas electronic filing system. Counsel also certified 

that he has provided Jolly Neely, a motion to obtain the record if he so chooses. 

IS/ James W. Huggler. Jr. 

James Huggler 

Michael West 

Smith County District Attorney's Office 

100 North Broadway, 4th Floor 

Tyler, Texas 75702 

Page 3 of 4 

Jolly Neely 

TDCJ #01967101 

Byrd Unit 

21 FM247 

Huntsville, Texas 77320 
Exhibit A 

Letter to J oily Neely 

Page4of 4 
JAMES Wo HUGGLER, JRo 

Board Certified in Criminal Law 

Board Certified in Criminal Appellate Law 

AprillO, 2015 

Jolly Neely 

TDCJ #01967101 

Byrd Unit 

21 FM 247 

Huntsville, Texas 77320 

RE: Jolly Neely v. State 

ATIORNEY AT LAW 

Appeal Number: 12-14,.00309-CR 

Trial Number: 007-04 79-14 

Dear Mr. Neely, 

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:ldata\Corcl User Filcs\Ciicnts\APPEALS\Nccly, Jolly Occ\Ciicni.Bricf.wpd 

First Place Building • 100 East Ferguson, Suite 805 • Tyler, Texas 75702 

903-593-2400 • www.jameshugglerlaw.com • Fax 903-593-3830