Luis Eduardo Lara v. State ( 2015 )

ACCEPTED
14-15-00581-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
11/3/2015 2:37:28 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS
FILED IN
FOR THE FOURTEENTH SUPREME JUDICIAL DISTRICT
14th COURT OF APPEALS
AT HOUSTON, TEXAS HOUSTON, TEXAS
11/3/2015 2:37:28 PM
CHRISTOPHER A. PRINE
LUIS EDUARDO LARA, § Clerk
§
Appellant §
§
vs. § CASE NOS. 14-15-00581-CR
§ 14-15-00582-CR
§ 14-15-00583-CR
§
§ TRIAL COURT NOS. 14CR2148
THE STATE OF TEXAS, § 14CR2149
§ 14CR2150
Appellee §
APPELLANT’S MOTION TO SUPPLEMENT REPORTER’S RECORD
AND ORDER BRIEF DUE THIRTY DAYS AFTER RECORD IS
SUPPLEMENTED
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF
APPEALS:
COMES NOW LUIS EDUARDO LARA, Appellant in the above-styled and
numbered cause, by his Counsel of Record, Greg Russell, and pursuant to
TEX.R.APP.P. 34.6(g)(2), and files this Motion to Supplement Record and in
support thereof would show this Honorable Court the following:
I.
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Appellant was found guilty by a jury of the offense of Sexual Assault of a
Child, Indecency with Child by Conduct and Continuous Sexual Abuse of a Child
and punishment was assessed by the Court at 15, 8 and 28 years, respectively,
Institutional Division – Texas Department of Criminal Justice.
II.
Appellant’s Brief is due on or before November 5, 2015.
III.
The Reporter’s record of Carol Castillo contains exhibits of a completely
different case, styled The State of Texas vs. Devane Salters.
IV.
The Reporter’s Record does not contain any of the exhibits from this case of
Luis Lara. During the Guilt-Innocence and Punishment phases of the trial, the
State and Appellant introduced various Exhibits (entire record). These exhibits
were not made part of the Reporter’s Record and consequently were not sent to the
court of appeals. (entire record) Appellant needs to review these exhibits as to
possible grounds of error on appeal.
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V.
TRAP 34.6(g)(2) provides that the record may be supplemented with
original exhibits if request is made by the appellate court or by a party. Also, see
Pitts v. State, 916 S.W.2d 507, 509-510. Because Appellant must inspect these
exhibits to determine possible grounds of error, Appellant hereby seeks
supplementation of this record.
RESPECTFULLY SUBMITTED,
/s/ Greg Russell
Greg Russell
711 59th Street
Galveston, Texas 77551
(409) 497-4743
(409) 497-4721 Fax
SBN: 17411550
ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE
As Attorney of Record for Appellant, I do hereby Certify that a true and correct
copy of the above and foregoing document was this date provided to the Attorney for
Appellee, by e-file service to Mr. Jack Roady, District Attorney of Galveston County
at the offices of the District Attorney of Galveston County, Texas, 600 59th Street,
Galveston, Tx. 77551, on the 3rd day of November 2015.
/s/ Greg Russell
Attorney for Appellant
CERTIFICATE OF COMPLIANCE
I do hereby certify that this brief is in compliance with rule 9.4(i) (3) of the
Texas Rules of Appellate Procedure because it is computer generated, and its
relevant portions contain 335 words.
/s/ Greg Russell
Greg Russell
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