Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 5/20/2015 1:49:27 PM DEBBIE AUTREY Clerk
*1 Fl LED GREGG couHTY. TEXAS NO. 44128-A STATE OF TEXAS § IN THE DISTRICT COUR § vs. GREGG COUNTY, TEXAS § §
ROBERT MOORHEAD § 188TH JUDICIAL DISTRICT I NOTICE OF APPEAL I • [ TO THE HONORABLE COURT:
Notice is hereby given that the Defendant, ROBERT MOORHEAD, appeals this case to the I i i
Sixth Court of Appeals in Texarkana. Respectfully submitted, SNOW E. BUSH, JR., P.C. 420 N. Center Street
l t Longview, TX 75601 PHONE: (903) 753-7006
i FAX: (903) 753-7278 I E-MAIL: jonathanwharton l@sbcglobal.net i l
J NATHANWHARTON ATE BAR NO. 24075764 ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing was served on the } <l day of Di~r.~~ Attorney's Office of Gregg County, counsel for appellee, on this the 4 - ,2015 , by mail.
*2 FILED GREGG COUNTY, TEXAS MAY 14 2015
CAUSE NO. 44128-A
STATE OF TEXAS § § §
v. § OF GREGG COUNTY, TEXAS § §
ROBERT JUSTIN MOORHEAD § 188th JUDICIAL DISTRICT
MOTION FOR NEW TRIAL
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes ROBERT JUSTIN MOORHEAD, Defendant, and files this Motion for New Trial in this case.
I.
1. Defendant would show the Court that there has been material error com!nitted that is calculated to injure the rights of Defendant.
II.
2. Defendant would show the Court that both the guilt/innocence verdict and the punishment verdict are contrary to the law and the evidence on the case. WHEREFORE, PREMISES CONSIDERED, ROBERT JUSTIN MOORHEAD prays that this Court grant him a new trial. Signature on next page *3 Respectfully submitted, BOYD & BROWN, P.C. BY: KE~~
State Bar No. 24076877
1215 Pruitt Place Tyler, Texas 75703 903/526-9000
903/526-9001 (FAX)
kevin.giddens@suddenlinkmail.com
CERTIFICATE OF SERVICE
*4 On May 14th, 2015, a true and correct copy of the foregoing instrument was served upon the following in accordance with Rule21 a of the Texas Rules of Civil Procedure. Mr. Carl Dorrough Hand Delivery
~ Ms. Debbie Garrett Facsimile GREGG COUNTY DISTRICT Certified Mail - RRR D ATTORNEY First Class Mail
D
101 E. Methvin, Suite 333 . D Via Overnight Longview, Texas 75605 (903) 236-8440 (903) 236-8490 (Fax)
*5 FI LED GREGG COUHTY. EXAS Snow E. Bush, Jr., P. C.
Attomey and Counselor at Law
Snow E. Bush, Jr. enter Street Board Certified Longview, Texas 75601 Texas Board of legal Speciali=ation (903) 753-7006 Civil Trial Law and (903) 753-7278 Personal Injury Trial Law E-Mail: snowbush@sbcglobal.net Jonathan Wharton
E-Mail: jonathanwharton l@sbcglobal.net Licensed in Texas and New York May 19, 2015 f
Via First Class Mail
Barbara Duncan Gregg County District Clerk P. 0. Box 711 Longview, TX 75606 Re: The State of Texas v. Robert Moorhead
Cause No.: 44128-A
I
Dear Ms. Duncan: I t Enclosed please find the original and one (1) copy of a Notice of Appeal for filing with the Court I I i in the matter referenced above. A self-addressed, stamped envelope is enclosed for returning the file-marked copy. Thank you for your kind attention to this matter.
Sincerely, ' [ r i
Rose West Legal Assistant to Jonathan Wharton
/rw Enclosures cc: District Attorney's Office (Via Facsimile 903-236-8490)
f Gregg County Courthouse ' I
101 E. Methvin, Suite 333
Longview, TX 75601
I
' l