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STATE OF TEXAS 

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NO. 29,984 lOIS S[p /f 

§ IN THE DISTRIST ~Q,URT 41111: I 0 

§ vt ~· rrw·r -:t y , . ~ .. •. ~. :::..r::·.;.~·~.;.:?u,.., 

~ 354th JUDICI~~~~~tH~N-r c::. r ... 

§ HUNT COUNTY, TEXAS ·1--, ·U l!;·, 

vs. 

JOSHUA MADISON NEWKIRK 

NOTICE OF APPEAL 

TO THE HONORABLE JUDGE OF SAID COURT: 

Now comes JOSHUA MADISON NEWKIRK, Defendant in the above styled and 

numbered cause, and gives this written notice of appeal to the Court of Appeals of the 

State of Texas from the judgment of conviction and sentence herein rendered against 

JOSHUA MADISON NEWKIRK. 

Notice of Appeal 

Page 1 of 2 

Respectfully submitted, 

Peter I. Morgan 

2708 Washington St. 

P.O. Box 984 

Greenville, Texas 75403 

Tel: (903) 455-8113 

Fax: (903) 642-0057 

ByP/~ Peter I. Morgan 

State Bar No. 14451700 

Attorney for JOSHUA MADISON NEWKIRK 

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 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 9/28/2015 8:28:40 AM DEBBIE AUTREY Clerk
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CERTIFICATE OF SERVICE 

This is to certify that on September 11, 2015, a true and correct copy of the above 

and foregoing document was served on the District Attorney's Office, Hunt County, 41

h Floor 

Hunt County Courthouse, by hand delivery. 

Notice of Appeal 

Page 2 of 2 

PI~ 

Peter I. Morgan 

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.~tr-!_fLt:o INCIDENT No.fi'RN: 9128362217 AOOl ~,.. ~AI 

CASE NO. 29984 COUNT 1 

THE STATE OF TEXAS § 

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IN THE DISTRICT C~~ltT ... ~ }Qf5 

cte: ~-:;"- .., 

"~•cs , 'l~ OF HUNT COUNTY, Tt~fL'tt. ••. t-~ j 

v. 

JOSHUA MADISON NEWKIRK ..... ~ .... • C:l.l'.\' 

STATEID No.: TX 50028780 354TH JUDICIAL DISTRICT 

TRIAL COURT'S CERTIFICATION OF DEFENDANT'S RIGHT OF APPEAL 

I, RICHARD A. BEACOM, JR. ,Judge of the trial court certify this criminal case: 

181 is not a plea bargain case, and the defendant has the right of appeal; or 

0 is a plea bargain case, but matters were raised by written motion filed and ruled on before trial and 

not withdrawn or waived and the defendant has the right of appeal; or 

0 is a plea bargain case, but the trial court has given permission to appeal; and the defendant has the 

right to appeal; or 

0 is a plea bargain case, and the defendant has NO right of appeal; or 

Signed 

O the defen~ant 

on 09-02-2015. 

ha.wa;ved the right ofappi'? ff: ~- ,tJ ~ 

~ 

. . HONORABLE R;CHAR.D A:BEACOMZ~ .. 354 TH JUDICIAL DISTRICT COURT - I have received a copy of this certification. I have also been informed of my rights. concerning-any 

appeal ofthis criminal case, including any right to file a prose petition for discretionary review pursuant to: 

Rule 68 of the Texas Rules of Appellate Procedure. I have been admonished that my auo·rney must mail a copy 

of the court of appeals' j~dgment and opinion to my last known address and I have only thirty (30) days in 

which to file a pro se petition for discretionary review in the court of appeals. TEX. R. APP. PRO. R. 68.2. I 

acknowledge that, if I wish to appeal this case and if I am entitled to do so, it is my duty to inform my appellate 

attorney, by written communication, of any change in the address at which 1 am currently living or any change 

in my prison unit. I understand that, because of appellate deadlines, if I fail to timely inform my appellate 

attorney of any change in my address, I may lose the opportunity to file a pro se petition for discretionary 

review. 

fendant (MUST SIGN) Attorney for Defendant 

Mailing Address: :25 0 / -7;1.~ <:; 7: SBN: -~~,a.c....:l'-'~"-'1_.1'-------- Cq(JJ" JV.:;I~, lS£ 751~ 

Telephone number: 9"'~ ~ 51:-7- c:JIB ( Address: PO BOX 1053 

GREENVILLE,TEXAS 75403-1053 

Telephone Number: 903-455·9888 

Fax Number: 903-454-7904 

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THE STATE OF TEXAS 

v 

JOSHUA MADISON 

NEWKIRK 

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MOTION FOR NEW TRIAL 

Joshua Madison Newkirk. Defendant, files this Motion For New Trial and shows: 

1. Trial Date and Conviction 

A trial before the court on this case was held and judgment pronounced and entered 

on September 2, 20 15. 

2. Grounds for New Trial 

Defendant requests that a new trial be granted in the interest of justice. Defendant 

urges the Court to reconsider whether or not sufficient evidence exists to support each 

element of the offense of Murder as charged in the indictment. 

Prayer 

Defendant prays that the Court set aside the Judgment of Conviction entered in this 

cause and order a new trial on the merits .. 

Motion For New Trial 

State ofTexas v. Joshua Madison Newkirk 

Page l of2 

Peter l. Morgan, 

Counsel for Joshua Madison Newkirk 

SBN 14451700 

P.O. Box 984 

2708 Washington St. 

Greenville. Texas 75403 

Tel: (903) 455-8l13 

Fax: (903) 642-0057 

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CERTIFICATE OF SERVICE 

This is to cenify that on September II, 2015, a true and correct copy of the above 

and foregoing document was served on the District Attorney's Office, Hunt County, 4th 

floor Hunt County Counhouse, by hand delivery. 

Motion For New Trial 

State of Texas v. Joshua Madison Newkirk 

Page 2 of2 

PJt~M~ Peter I. Morgan 

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