Lewis Lavon Jones v. State ( 2016 )

ACCEPTED
06-16-00110-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
9/9/2016 3:27:29 PM
DEBBIE AUTREY
CLERK
NO. 06-16-00110-CR
TRIAL NO. 2013-C-0310
LEWIS LAVON JONES FILED IN
IN THE COURT OF APPEALS
§ 6th COURT OF APPEALS
TEXARKANA, TEXAS
VS. § 6TH APPELLATE DISTRICT
9/9/2016 3:27:29 PM
DEBBIE AUTREY
STATE OF TEXAS § STATE OF TEXAS Clerk
APPELLANT'S COUNSEL'S MOTION TO WITHDRAW
Appellant's counsel, pursuant to Anders v. California, 386 U.S. 738 (1967), asks this Court
to permit him to withdraw from representation of Lewis Lavon Jones in the above referenced matter.
This motion is based on the following grounds:
A. Introduction
1. Appellant was convicted by a jury of the second degree felony offense of
Indecency with a Child by Sexual Contact in the Panola County Court at Law. The
trial court sentenced Appellant to 15 years in the Texas Department of Criminal
Justice- Institutional Division.
2. Attorney Kyle Dansby was appointed by the trial court as appellate attorney on
June 14, 2016.
3. In this appeal, appellate counsel is unable to advance any error wanting a reversal
of the sentence or any other form of relief for Appellant. Therefore, pursuant to
Anders v. California, he files this Appellant's Counsel's Motion to Withdraw in
support of motion to withdraw asking this Court to allow him to withdraw from his
representation of Appellant in this matter.
B. Grounds
4. Counsel has thoroughly read and reviewed the entire appellate record in search of
any arguable grounds of error to raise which would support either a reversal of the
sentence of some other form of relief. After performing due diligence and researching
the potential grounds for appeal, appellate counsel is unable to find any error that he,
in good faith, can put forth which warrants a reversal of the sentence of any other
form of relief. Appellate counsel is aware that he has a duty to present all arguable
grounds of error that would afford Appellant a reversal of his conviction of any other
form of relief.
C. Notice of Appellant of Motion
5. A copy of the Anders brief in support of motion to withdraw and corresponding
Motion to Withdraw have been forwarded to Appellant. See Exhibit A. Appellant
has also been advised that he has thirty days to file a pro se response or a motion
requesting an extension of time in which to file a response pursuant to Wilson v. State,
955 S.W.2d 693 (Tex. App. - Waco, 1997, order), disp on merits, 3 S.W.3d 223 (Tex.
App. - Waco 1999, pet ref d). See Exhibit A.
D. Prayer
WHEREFORE, PREMISES CONSIDERED, for these reasons, Appellant's
counsel requests that this Court grant this motion and enter an order withdrawing
below signed counsel from representation of Lewis Lavon Jones in the above
referenced matter and for any such relief that he may be entitled.
Respectfully Submitted
TY,
yleD by
Attorney at Law
P.O. Box 1914
Marshall, TX 75671
(903) 738-6162
(888) 410-1583 (fax)
kdansbylawgmail.com
SBN: 24059180
CERTIFICATE OF SERVICE
I, Kyle Dansby, attorney for Appellant, hereby certify that a true and correct copy of this
Motion to Withdraw has been forwarded to the following on the 9th day of September, 2016:
Tim Canker
Panola County District Attorney's Office
Via email to tim.cariker@co.panola.tx.us
Attorney for State
Terry Bailey: trial judge, County Court at Law, Panola County, Texas
108 S. Sycamore, Room 300
Carthage, TX 75633
Via email to erin.johnsonco.panola.tx.us
Lewis Lavon Jones Appellant
Joe F. Gurney Unit (TDC # 02070360)
1385 FM 3328
Palestine, TX 75803
K2
Attorney for Appellant
SBN: 24059180
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