KEITH WILLIAM BENNETT, 

APPELLANT 

vs. 

THE ST ATE OF TEXAS, 

APPELLEE 

NO. 44069-B 

§ 

§ 

§ 

NOTICE OF APPEAL 

FI LED 

GREGG COUtlTY. TEXAS 

IN THE DISTRIC 

124rn JUDICIAL DISTRICT 

GREGG COUNTY, TEXAS 

TO THE HONORABLE JUDGE OF SAID COURT: 

NOW COMES KEITH WILLIAM BENNETT, who was Defendant in the above styled and 

numbered cause, by and through his counsel, EBB B. MOBLEY, the trial court having granted 

permission to appeal, and files this notice that he wishes to appeal from the conviction to the Sixth 

Court of Appeals on errors raised by written motion and ruled on before trial and on errors arising 

during and subsequent to trial. 

Sentence was imposed on July 17, 2015, and this written Notice of Appeal is filed with the 

Clerk of this Court within 30 days of that date. 

Respectfully submitted, 

EBB B. MOBLEY 

Attorney at Law 

422 North Center Street-Lower Level 

P. 0. Box 2309 

Longview, TX 75606 

Telephone: (903) 757-3331 

Facsimile: (903) 753-8289 

ebbmob@aol.com 

EBB B. MOBLEY 

Attorney for Appellant 

State Bar License# 14238000 

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 7/22/2015 8:26:00 AM DEBBIE AUTREY Clerk
EBB B. MOBLEY 

ATTORNEY AT LAW 

422 NORTH CENTER STREET - LOWER LEVEL 

P. 0. BOX 2309 

July 21, 2015 

Tina Campbell 

Gregg County Court Reporter 

124th Judicial District Court 

101 East Methvin, Suite 447 

Longview, Texas 75601 

LONGVIEW, TEXAS 75606 

TELEPHONE: (90.)) 757-3331 

FAX: (903) 753-8289 

RE: Cause No. 44069-B 

State v. Keith William Bennett 

Dear Ms. Campbell: 

FI LED 

GREGG COUt1TY, TEXAS 

I have been appointed to represent the above Appellant on his appeal. I need a complete 

Reporter's Record of this case, including all pre-trial hearings, arguments of counsel, voir dire of the 

jury, and any exhibits entered into the record. 

Thank you for your attention to this matter. 

Very truly yours, 

Ebb B. Mobley 

/kk 

cc: Mr. Carl Dorrough 

Gregg County District Attorney 

101 East Methvin. Suite 333 

Longview, Texas 75601 

V" Ms. Barbara Duncan 

Gregg County District Clerk 

I 01 East Methvin, Suite 334 

Longview, Texas 75601 

~ Keith William Bennett 

Gregg County Jail 

101 East Methvin, Suite 635 

Longview, Texas 75601 
THE ST ATE OF TEXAS 

vs. 

NO. 44069-B 

§ IN THE DISTRICT COURT 

124rn JUDICIAL DISTRICT 

KEITH WILLIAM BENNETT 

§ 

§ GREGG COUNTY, T~E D 

GREGG COUNTY, TEXAS 

MOTION FOR NEW TRIAL 

TO THE HONORABLE JUDGE OF SAID COURT: 

BY 

COMES NOW KEITH WILLIAM BENNETT, Defendant, by and throug·~--,.,,.......'--

attorney for appeal, and files this Motion for New Trial in this case. 

I. 

Defendant would show the Court that there has been material error committed that is 

calculated to injure the rights of Defendant. 

II. 

Defendant would show the Court that both the guilt/innocence verdict and the punishment 

verdict are contrary to the law and the evidence in the case. 

III. 

Defendant would show the Court that the sentence is so disproportionate as to constitute cruel 

and unusual punishment in violation of the Texas and U.S. Constitutions. The trial court exhibited 

bias in failing to consider the entire range of punishment. 

PRAYER 

WHEREFORE, PREMISES CONSIDERED, Defendant prays that this Motion for New Trial 

be set for hearing, and, upon hearing, that the Court grant him a new trial. 

Respectfully submitted, 

EBB 13. MOBLEY 

Attorney at Law 

422 North Center Street-Lower Level 

P. 0. Box 2309 

Longview, TX 75606 

Telephone: (903) 757-3331 

Facsimile: (?03) 753-8289 

ebbmob a ol.com 

EBB B. MOBL 

Attorney for Defendant 

State Bar License# 14238000 

CERTIFICATE OF SERVICE 

I, the undersigned, hereby certify that a true and correct copy of the foregoing motion was 

forwarded to the office of Zan Colson Brown, Gregg Coufl!)' tssistant District Attorney, 101 East 

Methvin, Suite 333, Longview, Texas 75601, on this t . (JV day of July, 2015, by efile. 

Isl EB BLEY 

EBB B. MOBLEY 
THE STATE OF TEXAS 

vs. 

KEITH WILLIAM BENNETT 

NO. 44069-B 

§ 

§ 

§ 

IN THE DISTRICT COURT 

124rn JUDICIAL DISTRICT 

GREGG COUNTY, TEXA~ \LE 0 

GREGG co~TY. TEXAS 

DESIGNATION OF RECORD ON APPEAL 

TO THE HONORABLE JUDGE OF SAID COURT: 

I. A complete Reporter's Record of the trial of this cause, the voir dire examination of the jury, the final 

argument of counsel, any pre-trial or post-trial hearings, or any other matters connected with this case 

where the court reporter was present and transcribing the proceedings. 

2. The indictment. 

3. Any special pleas and motions of the Defendant and motions of the State. 

4. Any written waivers. 

5. Court's docket sheet. 

6. Charge of Court on both guilt or innocence and punishment. 

7. Any special requested charges submitted by the Defendant. 

8. The verdict of the jury. 

9. Court's Findings of Fact and Conclusions of Law. 

I 0. Court's judgment and sentence. 

I I. Motions for New Trial. 

12. Notice of Appeal. 

13. Letter to court reporter requesting preparation of Reporter's Record. 

14. Any notes from the jury and the Court's responses thereto. 

15. All exhibits. 

16. All juror information sheets and information on peremptory strikes. 

17. Any other matter contained within the Court's files. 

18. Any order appointing a visiting or retired Judge to preside on this case. 

19. Any presentence investigation prepared for and used in this case. 

20. Trial Court's Certification of Defendant's Right of Appeal. 

WHEREFORE, PREM !SES CONSIDERED, the Defendant respectfully requests that these matters be contained 

within the record of this appeal. 

Respectfully submitted, 

CERTIFICATE OF SERVICE 

I, the ""de.'{f ff d, heceby oertHY that a true aod correct copy of the above and focego;"g w"' fon<acded to the 

office of Zan Colso . r wn, Gregg County Assistant District Attorney, I 0 I East Methvin, Suite 333, Longview, Texas 

75601, on this the day of July, 2015, by efile. (}, JAL. 

/s/ 'Jl::.~~J~~ / 

-'-E"'"B-B-"B=. M~O"--B-'-'-L!..OE"-'Y~,"""~~"""o-'-u-n-s..u-fi-o-r -D-e-fe-n-da_n_t ______ _