Fears, Ronald Blake ( 2015 )

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