Richard Lares v. State ( 2015 )

NO. 04-15-00183-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS RICHARD LARES, Appellant V. THE STATE OF TEXAS, Appellee RESPONSE TO ORDER DENYING ~ " ■ ■ - — MOTION TO STAY JUDGMENT AND CONVICTION TO THE HONORABLE JUSTICES OF SAID COURT: Now Comes, Richard Lares, TDCJ #1592255, Appellant herein, in style and cause number and files this Response to Order Denying Motion to Stay Judgment and Conviction and in support shows the following: Appellant, Lares, is Not being represent by counsel because the court appointed cousel, Mr. Barry P. Hitchings, withdrew representation on June 12,2015 and put appellant back on Pro Se status. Said Counsel filed Anders Brief with out interviewing appellant and without visiting appellant and denied appellant an opporturnity to explain the circumstances of the case. Appellant is requesting that his Motion to Stay Judgment and Conviction be reconsidered since appellant is Pro Se. Appellant did not submit hybrid Motion and is currently working on Appel lant Brief on Appeal since appointed counsel withdrew. Prayer WHEREFORE PREMISES CONSIDERED, Appellant Prays that the Honorable Justices rec onsider appellant's Motion to Stay Judgment and Conviction and Grant said Motion since Appellant is without representation. Further Appellant Court Appointed Counsel never mention that Appellant suffers from Mental Illness and Disorders and abandoned his client witout personally interviewing him. SO MOVED, SO PRAYED FOR. Sincerely Submitted, 6£ Richard Lares, Pro Se CERTIFICATE OF SERVICE I have read the pleadings and to the best of my knowlidge and belief, for med after reasonable inquiry, that the instrument is not groungless, or brought- in bad faith or brought for the purpose of harrassment, unnecessary delay,jor any other improper purpose. That on July 8, 2015 a true and correct copy was sent by U.S. Postal Mail to the Fourth Court of Appeals Clerk at Cadena-Reeves Justice Center, 300 Dolorosa, Suite 3200, San Antonio, Texas 78205-3037. Respectfully, Richard Lares, #1592255 Pack 1 Unit 2400 Wallace Pack Rd. Navasota, Texas 77868 "De Oppresso Liber" U.S. Army Combat Veteran C lexk ftiutti Ccur]- ; 7-r-/r \_ trei M. 4, / J x ^ 1',Ve «~V t, 4r>r /v / 09 3Ut 2O2.S FM 7 i. Uc\[ ccc 7B205303733