Crae Robert Pease v. State

Opinion

November 16, 2015

Cause No. 03-14-00512-CR

CRAE ROBERT PEASE Appellant

v.

/RECEIVED \ THE STATE OF TEXAS NOV 1 6 Z015 Appellee THIRD COURT OF APPEALS. BaKYLE"^APPELLANT'S 2nd MOTION TO SUPPLEMENT THE RECORD AND EXTENSION OF TIME TO FILE APPEAL

TO THE HONORABLE COURT OF APPEALS:

Crae Robert Pease, Appellant, makes this Motion to Supplement the Record in

Support of Appellant's Brief, pursuant to Rule 10.1 and 10.2, Tex.R.App.Proc,

and as grounds therefore would show the Court:

I.

This cause was heard in the Travis County Court at Law No. 6 in August 11,

2014 under trial court Cause No. C-l-CR-13-220, styled The State ofTexas v. Crae

Robert Pease.

II.

While preparing his appeal, which he planned to file today, Appellant found

that there was no Reporter's Record for a hearing on July 11, 2014.

III.

The hearing was to question the validity of the information, which was

altered at the hearing on July 11, 2014. Because there are irregularities in information which were preserved on the record of that date, Appellant requires the

Reporter's record from that date in order to complete his appeal.

This request is not meant for purposes of delay, but to verify and document

appellant issues.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court

will grant this Motion and supplement the record with the Reporter's record of July

11,2014 and extend the time to file his brief to one week after the record is filed.

Respectfully submitted,

Crae Robert Pease 6715 Skynook Drive Austin, Texas 78745

CERTIFICATE OF CONFERENCE

On November 16, 2015, Appellant conferred with William Swaim, attorney

for Appellee, and Mr. Swaim responded that he had no objection to the extension

of time.

Crae Robert Pease CERTIFICATE OF SERVICE

On November 16, 2015, a copy of the attached motion for extension of time was sent by U. S. Postal Service to:

William Swaim Travis County Attorney's Office P.O. Box 1748 Austin, Texas 78767 Nothing in the information establishes the supposition that Travis County courts have

jurisdictionover this matter, therefore, the information is defective, the defect is of a jurisdiction

nature, and therefore must be quashed. Brown v. State, 558 S.W.2d 471 (Tex.CrApp.1977).

Crae Robert Pease

CERTIFICATE OF SERVICE

I, the undersigned, hereby certify that a true and correct copy of the attached Motion to Quash information was sent by e-mail and personal service on July 11, 2014 to:

Travis County Special Prosecutor Bill Swaim

Travis County chief Prosecutor County Court at Law #6. Randall Slagle Nothing in the information establishes the supposition that Travis County courts have

jurisdiction over this matter, therefore, the information is defective, the defect is of a jurisdiction

nature, and therefore must be quashed. Brown v. State, 558 S.W.2d 471 (Tex.Cr.App.1977).

I, the undersigned, hereby certify that a true and correct copy of the attached Motion to Quash information was sent by e-mail and personal service on July 11,2014 to:

Travis County chief Prosecutor County Court at Law #6. Randall Slagle ._.—--