Shadondra Jenkins v. State

ACCEPTED
12-14-00295-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
2/27/2015 11:50:17 AM
CATHY LUSK
CLERK
IN THE COURT OF APPEALS
THE TWELFTH DISTRICT OF TEXAS FILED IN
12th COURT OF APPEALS
TYLER, TEXAS
TYLER, TEXAS 2/27/2015 11:50:17 AM
CATHY S. LUSK
Clerk
SHADONDRA JENKINS CASE NO. 12-14-00295
V. TRIAL COURT NO
THE STATE OF TEXAS CR 2013-0615
APPEALED FROM THE 159TH DISTRICT COURT
OF ANGELINA COUNTY, TEXAS
THE HONORABLE PAUL WHITE, JUDGE PRESIDING
MOTION TO WITHDRAW
TO THE HONORABLE COURT OF APPEALS;
COMES NOW, John D. Reeves, court appointed attorney on appeal for
Shadondra Jenkins Appellant, and pursuant to Anders v. California, 386 U.S. 738
(1967). Johnson v. State, 885 S.W.2d 641 (Tex. App.-Waco 1994, and Stafford v.
State 813 S.W.2d 503 (Tex. Crim. App. 1999), files this Motion to Withdraw, and
for good cause shows this Honorable Court the following:
I . FACTS
1. Appellant Shadondra Jenkins was indicted with a two count indictment for two
offenses of Injury to a Child on October 31, 2013.
2. Appellant Shadondra Jenkins waived arraignment for the each offense of Injury
to a Child on November 13, 2013 and entered a plea of not guilty.
3. Appellant, Shadondra Jenkins, signed a waiver of jury trial on April 14th, 2014
which was approved by the trial court.
4. Appellant, Shadondra Jenkins, entered a plea of guilty to the indictment of
Injury to a Child, (two counts) on May 20th, 2014 and she received one hundred
and fourteen months in the ID-TDCJ on October 3, 2014.
5. On October 14th, 2014an Order appointing John D. Reeves as appellate
counsel was entered by the trial court.
6. On October 9th, 2014 trial counsel filed a Notice of Appeal.
7. The order for designation of records was signed by the trial court on October
24th, 2014 for the Clerk’s Record and the Reporter’s Record.
8. On February 24th, 2015 counsel for Appeal counsel filed an Anders brief on
behalf of Appellant with this Honorable Court, and forwarded a copy of the brief to
appellant explaining her rights regarding pro se brief and Discretionary Review.
II. ARGUMENT
9. In accordance with the requirements of Anders v. California, 386 U.S. 738
(1967), and Johnson v. State, 885 S.W.2d 641 (Tex. App.-Waco 1994) counsel for
requests this Honorable Court to allow him to withdraw.
10. Appellant’s address is:
Shadondra Jenkins
Marlin Unit
TDC # 01962913
2893 State Hwy 6
Marlin, Texas 76661
11. Counsel for Appellant has forwarded a copy of the Anders brief to Appellant
to Appellant.
12. Good cause exists to relieve counsel, John D. Reeves, counsel for Appellant
from his representation of appellant Shadondra Jenkins. Specifically, counsel for
Appellant can find no arguable grounds to support an appeal and finds after a
thorough review of the record that any issue brought forth would be without merit
and frivolous.
III. PRAYER
WHEREFORE, PREMISES CONSIDERED, counsel for Appellant prays that this
Honorable Court grant his Motion to Withdraw without harm to the rights
guaranteed Shadondra Jenkins by the United States Constitution and the
Constitution of the State of Texas.
Respectfully Submitted,
/s/John D. Reeves
John D. Reeves
SBN # 16723000
1007 Grant Avenue
Lufkin, Texas 75901
Ph: (936) 632-1609
Fax: (936) 632-1640
Email: tessabellus@yahoo.com
CERTIFICATE OF SERVICE
I hereby certify that on the foregoing instrument was mailed by e-filing on this the
27th day of February 2015 to the following counsel and parties of record.
Mr. April Ayers-Perez /s/John D. Reeves
Angelina Asst. District Attorney _______________________
P.O. Box 908 John D. Reeves
Lufkin, Texas 75901
Shadondra Jenkins
TDC # 01962913
2893 State Hwy 6
Marlin, Texas 76661