Robert Justin Moorhead v. State

Opinion

Fl LED

GREGG couHTY. TEXAS

NO. 44128-A

STATE OF TEXAS § IN THE DISTRICT COUR § FILED IN 6th COURT OF APPEALS

vs. § GREGG COUNTY, TEXAS TEXAS TEXARKANA,

§ 5/20/2015 1:49:27 PM ROBERT MOORHEAD § 188TH JUDICIAL DISTRICT DEBBIE AUTREY

NOTICE OF APPEAL

Clerk

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TO THE HONORABLE COURT:

Notice is hereby given that the Defendant, ROBERT MOORHEAD, appeals this case to the

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Sixth Court of Appeals in Texarkana.

Respectfully submitted,

SNOW E. BUSH, JR., P.C. 420 N. Center Street Longview, TX 75601 PHONE: (903) 753-7006

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FAX: (903) 753-7278 i E-MAIL: jonathanwharton l@sbcglobal.net Ii

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J NATHANWHARTON

ATE BAR NO. 24075764 ATTORNEY FOR DEFENDANT

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing was served on the Di~r.~~ Attorney's Office of Gregg County, counsel for appellee, on this the } <l day of 4 - , 2 0 1 5 , by mail.

FILED

GREGG COUNTY, TEXAS

MAY 14 2015

CAUSE NO. 44128-A

STATE OF TEXAS § § §

v. § OF GREGG COUNTY, TEXAS § §

ROBERT JUSTIN MOORHEAD § 188th JUDICIAL DISTRICT

MOTION FOR NEW TRIAL

TO THE HONORABLE JUDGE OF SAID COURT:

Now comes ROBERT JUSTIN MOORHEAD, Defendant, and files this Motion for New

Trial in this case.

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1. Defendant would show the Court that there has been material error com!nitted that

is calculated to injure the rights of Defendant.

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

punishment verdict are contrary to the law and the evidence on the case.

WHEREFORE, PREMISES CONSIDERED, ROBERT JUSTIN MOORHEAD prays

that this Court grant him a new trial.

Signature on next page

Respectfully submitted,

BOYD & BROWN, P.C.

BY: KE~~ State Bar No. 24076877 1215 Pruitt Place Tyler, Texas 75703 903/526-9000 903/526-9001 (FAX) kevin.giddens@suddenlinkmail.com

CERTIFICATE OF SERVICE

On May 14th, 2015, a true and correct copy of the foregoing instrument was served upon the following in accordance with Rule21 a of the Texas Rules of Civil Procedure.

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Mr. Carl Dorrough Hand Delivery Ms. Debbie Garrett Facsimile GREGG COUNTY DISTRICT D Certified Mail - RRR ATTORNEY D First Class Mail 101 E. Methvin, Suite 333 . D Via Overnight Longview, Texas 75605 (903) 236-8440 (903) 236-8490 (Fax)

FI LED

GREGG COUHTY. EXAS

Snow E. Bush, Jr., P. C.

Attomey and Counselor at Law Snow E. Bush, Jr. enter Street Board Certified Longview, Texas 75601 Texas Board of legal Speciali=ation (903) 753-7006 Civil Trial Law and (903) 753-7278 Personal Injury Trial Law E-Mail: snowbush@sbcglobal.net

Jonathan Wharton E-Mail: jonathanwharton l@sbcglobal.net Licensed in Texas and New York

May 19, 2015

Via First Class Mail f Barbara Duncan Gregg County District Clerk P. 0. Box 711 Longview, TX 75606

Re: The State of Texas v. Robert Moorhead Cause No.: 44128-A

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Dear Ms. Duncan:

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Enclosed please find the original and one (1) copy of a Notice of Appeal for filing with the Court

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in the matter referenced above. A self-addressed, stamped envelope is enclosed for returning the file-marked copy.

Thank you for your kind attention to this matter.

Sincerely,

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Rose West Legal Assistant to Jonathan Wharton /rw Enclosures

cc: District Attorney's Office (Via Facsimile 903-236-8490)

Gregg County Courthouse f 101 E. Methvin, Suite 333 '

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Longview, TX 75601

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