Michael Dean Raglin v. State ( 2015 )

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NO. 1122316
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STATE OF TEXAS § IN THE DISTRICT COU~T T' 9 P/1 J .
FILED IN
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6th COURT OF APPEALS
ir . ~T· TEXAS
TEXARKANA,
8TH JUDICIAL DISTruk
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vs. §
§ 10/13/2015 11:47:24
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MICHAEL DEAN RAGLIN § HOPKINS COUNTY, TEXAS
DEBBIE AUTREY
Clerk
NOTICE OF APPEAL
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes Michael Dean Raglin, 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 Michael Dean Raglin.
Respectfully submitted,
LAW OFFICE OF JONATHAN A. NEWSOM
216 Davis Street North
SULPHUR SPRINGS, TX 75482
Tel: (903) 951-1851
Fax: (903) 951-1852
By~. ~
JOI1anA.ewsoin
State Bar No. 2408 1067
jonathan@newsomlaw.net
Attorney for Michael Dean Raglin
CERTIFICATE OF SERVICE
This is to certify that on October 9, 2015, a true and correct copy of the above and
foregoing document was served on the District Attorney's Office, Hopkins County, 110 Main
Street, Sulphur Springs, Texas 75482, by hand delivery.
Jonathan A. Newsom
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NO. 1122316 2015 Der ...
STATE OF TEXAS § IN THE DISTRICT co~ 3: Do
§ -
I s'.'
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•
vs. § 8TH JUDICIAL DISTRICT
§
MICHAEL DEAN RAGLIN § HOPKINS COUNTY, TEXAS
MOTION TO WITHDRAW
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes Jonathan A. Newsom, Movant and attorney of record for Defendant, Michael
Dean Raglin, brings this Motion to Withdraw as counsel and in support thereof shows:
1. Movant was appointed by the Court to represent Defendant in the trial of this
cause.
2. Defendant, Michael Dean Raglin, Suspended Sentence was revoked and was
sentenced to 10 years on September 22, 2015. Movant has advised Michael Dean Raglin of his
right to appeal in this cause.
3. The following deadlines and/or settings exist in this case:
a. To file Notice of Appeal: Filed on October 9, 2015.
b. To file a Motion for New Trial: October 22, 2015.
4. Movant and Defendant request the Court appoint an attorney to represent
Defendant in his appeal in this case, because he is indigent and cannot afford to employ counsel.
Defendant's Affidavit of Indigence is already on file with the papers in this cause and there has
been no change in his financial ability to hire an attorney to represent him in this case.
5. Movant has advised Defendant of his right to file a motion for new trial and a
notice of appeal; that Movant will assist in requesting prompt appointment of replacement
counsel if Defendant wishes to file a motion for new trial and/or a notice of appeal; and, if
..
replacement counsel is not appointed promptly and Defendant wishes to pursue an appeal,
Movant will file a timely notice of appeal.
6. A copy of this motion has been hand delivered to him by Movant.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Movant prays that the Court allow
Jonathan A. Newsom to withdraw as counsel for Michael Dean Raglin and from any further
representation of Michael Dean Raglin in this cause. Defendant and Movant further pray the
Court appoint counsel to represent Defendant in the appeal of this case.
Respectfully submitted,
LAW OFFICE OF JONATHAN A. NEWSOM
216 Davis Street North
SULPHUR SPRINGS, TX 75482
Tel: (903) 95 1-1 851
Fax: (903) 951-1852
By~
State Bar No. 24081067
j onathan@newsornlaw.net
Attorney for Michael Dean Raglin
CERTIFICATE OF SERVICE
This is to certify that on October 9, 2015, a true and correct copy of the above and
foregoing document was served on the District Attorney's Office, Hopkins County, 110 Main
Street, Sulphur Springs, Texas 75482, by hand delivery.
N0.1122316
2015 OCT - 9 PH 4: 25
STATE OF TEXAS § IN THE DISTRICT COURT
§
vs. § 8TH JUDICIA~DIS.rtkfcT J • • • ' .....
§
MICHAEL DEAN RAGLIN § HOPKINS COUNTY, TEXAS
ORDER
, 2015, came on to be considered Jonathan A. Newsom's Motion to
Withdraw, and said motion is hereby
e (Denied)