Fears, Ronald Blake

Opinion

PD-0598-15

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 7/15/2015 12:44:38 PM Accepted 7/17/2015 1:16:34 PM ABEL ACOSTA

NO. PD-598-15 CLERK

RONALD BLAKE FEARS § IN THE §

VS. § COURT OF CRIMINAL § APPEALS

§

STATE OF TEXAS § AUSTIN, T E X A S

MOTION TO SUBSTITUTE COUNSEL TO THE HONORABLE JUDGE OF SAID COURT:

Now comes DOUGLAS H. PETTIT, Movant and attorney of record for Defendant, RONALD BLAKE FEARS, and brings this Motion to Substitute Counsel and in support thereof shows:

1. Movant was attorney of record for Defendant in the Appeal and has filed a request for Discretionary Review of this cause, and desires to withdraw from this cause.

2. Movant's attorney has accepted employment with the Cameron County District Attorney's Office beginning August 1, 2015. Counsel has accepted this a pro bono PDR and has not accepted any money from the Movant and will not be seeking any reimbursement.

3. Abigail Molina has agreed to take over the case and continue as required by this Honorable Court.

July 17, 2015

4. Such withdrawal is sought in order to permit Abigail D. Molina to be substituted as counsel of record for Defendant. The mailing address, telephone number, fax number and State Bar of Texas identification number for Abigail D. Molina are as follows:

ABIGAIL D. MOLINA

1257 N. SAM HOUSTON SAN BENITO, Texas 78586 (956) 564 9060 telephone

(956) 866 709 9503 fax

Texas State Bar No. 24074740

3. A copy of this motion has been mailed by certified mail and by regular mail to Defendant at Defendant's last known address:

Mr. Ronald Blake Fears TDC Number 01883420 Texas Department of Criminal Justice Mark Stiles Unit 3060 F.M. 3514 Beaumont, Texas 77705

PRAYER

WHEREFORE, PREMISES CONSIDERED, Movant prays that the Court allow DOUGLAS H. PETTIT to withdraw as counsel for RONALD BLAKE FEARS and from any further representation of RONALD BLAKE FEARS, and permit Abigail D. Molina to be substituted as counsel of record herein.

Respectfully submitted,

_/s/ Douglas H. Pettit

680 East St. Charles Suite 600 BROWNSVILLE, TX 78520

Tel: (956) 243-6455

Email: dpettitlaw@hotmail.com Attorney for RONALD BLAKE FEARS

_/s/ Abigail D. Molina

1257 N.Sam Houston

San Benito, Texas 78586

Tele (956) 564-9060

Fax (866) 709 9503

CERTIFICATE OF SERVICE

This is to certify that on July 15, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Cameron County, by hand delivery.

/s/ Douglas H. Pettit

Douglas H. Pettit

Attorney at Law

CERTIFICATE OF SERVICE

This is to certify that on July 15, 2015, a true and correct copy of the above and foregoing document was served on the State Prosecuting Attorney by mail.

/s/ Douglas H. Pettit

Douglas H. Pettit

NO. PD-598-15

STATE OF TEXAS § IN THE §

VS. § COURT OF CRIMINAL § APPEALS

§

RONALD BLAKE FEARS § AUSTIN, T E X A S

ORDER

On ___________________, 2015, came on to be considered DOUGLAS H.

PETTIT's Motion to Substitute Counsel, and said motion is hereby (Granted) (Denied)

JUDGE PRESIDING