Luis Eduardo Lara v. State

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.

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.

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

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