*1 RECEIVED IN The Court of Appeals Sistri District
FEB 132015
FAIR COURT CASE NUMBER 2, 68959, FEB 132015
STATE OF TEXAS
RECEIVED IN The Court of Appeals Sistri District
FEB 132015
FAIR COURT CASE NUMBER 2, 68959, FEB 132015
STYLE & MARKEN FRANK HALL X MATION FOR US. APRGINTMENT OF THE STATE OF TEXAS X COUNSEL
PURSUANT TO TEXAS RULE OF APPELLATE PROCEDURE APPELLANT MOVES FOR AN ORDER APRGINTENE COUNSEL TO REPRESENT HIM IN THIS CASE. IN SUPERFY OF THIS MOTION, APPELLANT STATES: (A) APPELLANT IS UNABLE TO AFRON COUNSEL, HE HAS REQUESTED LEAVE TO PROCEED IN FORMA PHIPERT. (B). APPELLANT'S IMPRESONMENT WILL GREATEY LIMIT HIS ABILITY TO LITIGATE. THE ISSUES INVOLVED IN THIS CASE ARE COMPIER, AND WILL REQUESTED SIGNIFICANT RESEARCH AND INVESTIGATION. APPELLANT HAS LIMITED ACCESS TO THE LAW LIGRARY AND LIMITED KNOWLEDGE OF THE LAW. (3). A TRIAL IN THIS CASE WILL LIKELY INVOLUE CONFICCTING TESTIMONY, AND COUNSEL WOULD BETTER ENADLE APPELLANT TO PRESENT EVIDENCE AND CROSS EXAMINE WITHESSES. (W)APPELLANT HAS MADE REPEATED EFRONDS TO OBTAIN A LAWYER.
WHEREFORE APPELLANT REQUEST THAT THE COURT APPEIY KEN STARR, A MEMBER OF THE TEXAS BAK, AS COUNSEL
*2
In this case.
EeE. 4,2015
MaNn: 1 HxII
MARUIN FRANK HALE-PRO-SE TOCTID - 1859577 ByRD UNIT 21. Fx 247
HUNTSUILLE, TEXAS 77320
CERTIFICATE OF PRESENTMENT
By StENATURE ABOVE, I HEREBY CERTIFY THAT A TRUE AND CORRECT COPY OF THE ABOVE AND FOREBOTNE HIS BEEN MAILED TO THE CLEXK FOR THE STH DISTRICT COURT OF MOUNT VERNON, FRANKLIN COUNTY, TEXAS, ON THIS DAY FEBRUARY 4,2015.
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY THAT ON FEBRUARY 4,2015, A TRUE AND CORRECT COPY OF THIS NOTION WAS MAILED AND SERVED ON THE FRANLIN COUNTY, TEXAS, DISTRICT ATTONEY'S OFFICE.
DECLARATION
I, MARUIN FRANK HALL, BEZWE PRESENTLY INCARCERATED IN THE TEXAS DEPARTMENT OF CRZMINAL TUSTICE, DECLARE UNDER PENJURY THAT THE ABOVE MOTION FOR ABOENT OF COUNSEL IS TRUE AND CORRECT.
EXECUTED ON FEBRUARY 4,2015.