PD-0591-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/24/2015 12:37:15 PM Accepted 7/24/2015 4:30:27 PM ABEL ACOSTA NO. PD-0591-15 CLERK ABRAHAM PARRA § IN THE § VS. § COURT OF CRIMINAL § APPEALS § STATE OF TEXAS § AUSTIN, T E X A S

MOTION TO SUBSTITUTE COUNSEL TO THE HONORABLE JUDGE OF SAID COURT: Now comes DOUGLAS H. PETTIT, Movant and attorney of record for Defendant, ABRAHAM PARRA, and brings this Motion to Substitute Counsel and in support thereof shows: 1. Movant was attorney of record for Defendant in the Appeal and has filed a request for Discretionary Review of this cause, and desires to withdraw from this cause.

2. Movant's attorney has accepted employment with the Cameron County District Attorney's Office beginning August 1, 2015. Counsel has accepted this a pro bono PDR and has not accepted any money from the Movant and will not be seeking any reimbursement.

3. Abigail Molina has agreed to take over the case and continue as required by this Honorable Court.

July 24, 2015 4. Such withdrawal is sought in order to permit Abigail D. Molina to be substituted as counsel of record for Defendant. The mailing address, telephone number, fax number and State Bar of Texas identification number for Abigail D.

Molina are as follows: ABIGAIL D. MOLINA 1257 N. SAM HOUSTON SAN BENITO, Texas 78586 (956) 564 9060 telephone (956) 866 709 9503 fax Texas State Bar No. 24074740 3. A copy of this motion has been mailed by certified mail and by regular mail to Defendant at Defendant's last known address: Mr ABRAHAM PARRA TDC Number 1874148 Texas Department of Criminal Justice 3872 F.M. 350 S, Livingston, Texas 77351 PRAYER WHEREFORE, PREMISES CONSIDERED, Movant prays that the Court allow DOUGLAS H. PETTIT to withdraw as counsel for ABRAHAM PARRA and from any further representation of ABRAHAM PARRA, and permit Abigail D. Molina to be substituted as counsel of record herein.

Respectfully submitted, _/s/ Douglas H. Pettit East St. Charles Suite 600 BROWNSVILLE, TX 78520 Tel: (956) 243-6455 Email: [email protected] Attorney for RONALD BLAKE FEARS

_/s/ Abigail D. Molina 1257 N.Sam Houston San Benito, Texas 78586 Tele (956) 564-9060 Fax (866) 709 9503

CERTIFICATE OF SERVICE This is to certify that on July 24, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Cameron County, by hand delivery.

/s/ Douglas H. Pettit Douglas H. Pettit Attorney at Law CERTIFICATE OF SERVICE This is to certify that on July 24, 2015, a true and correct copy of the above and foregoing document was served on the State Prosecuting Attorney by mail.

/s/ Douglas H. Pettit Douglas H. Pettit NO. PD-0591-15 STATE OF TEXAS § IN THE § VS. § COURT OF CRIMINAL § APPEALS § ABRAHAM PARRA § AUSTIN, T E X A S ORDER On ___________________, 2015, came on to be considered DOUGLAS H.

PETTIT's Motion to Substitute Counsel, and said motion is hereby (Granted) (Denied)

JUDGE PRESIDING