The opinion
Fl LED
GREGG couHTY. TEXAS
NO. 44128-A
STATE OF TEXAS § IN THE DISTRICT COUR
§ FILED IN
6th COURT OF APPEALS
vs. § GREGG COUNTY, TEXAS TEXAS
TEXARKANA,
§ 5/20/2015 1:49:27 PM
ROBERT MOORHEAD § 188TH JUDICIAL DISTRICT
DEBBIE AUTREY
NOTICE OF APPEAL
Clerk
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TO THE HONORABLE COURT:
Notice is hereby given that the Defendant, ROBERT MOORHEAD, appeals this case to the
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Sixth Court of Appeals in Texarkana.
Respectfully submitted,
SNOW E. BUSH, JR., P.C.
420 N. Center Street
Longview, TX 75601
PHONE: (903) 753-7006
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FAX: (903) 753-7278 i
E-MAIL: jonathanwharton l@sbcglobal.net Ii
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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
Di~r.~~ Attorney's Office of Gregg County, counsel for appellee, on this the } <l day of
4 - , 2 0 1 5 , by mail.
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.
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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
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
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.
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Mr. Carl Dorrough Hand Delivery
Ms. Debbie Garrett Facsimile
GREGG COUNTY DISTRICT D Certified Mail - RRR
ATTORNEY D First Class Mail
101 E. Methvin, Suite 333 . D Via Overnight
Longview, Texas 75605
(903) 236-8440
(903) 236-8490 (Fax)
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
Via First Class Mail f
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
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Dear Ms. Duncan:
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Enclosed please find the original and one (1) copy of a Notice of Appeal for filing with the Court
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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,
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Rose West
Legal Assistant to Jonathan Wharton
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Enclosures
cc: District Attorney's Office (Via Facsimile 903-236-8490)
Gregg County Courthouse f
101 E. Methvin, Suite 333
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Longview, TX 75601
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