Burrus v. State
In Burrus v. State, 266 S.W.3d 107, 115-16 (Tex. App.--Fort Worth 2008, no pet.), the court addressed whether presentment was established by a statement in a motion for new trial titled "Certificate of Presentment" along with a notation in the docket sheet stating that the motion for new trial was filed.
The court determined the certificate of presentment and the docket sheet notation were insufficient to establish that the trial court received actual notice of the motion for new trial and held the trial court did not err by failing to hold a hearing on appellant's motion for new trial. Id.