Donovan, Lawrence

• Court: Court of Appeals of Texas
• Decided: January 8, 2015
• Docket: PD-0474-14
• Status: Published

Opinion

COURT OF CRIMINAL APPEALS January 8, 2015 AUSTIN, TEXAS Transmitted 12/30/2014 1:26:35 PM Accepted 12/31/2014 12:14:48 PM IN THE TEXAS COURT OF CRIMINAL APPEALS ABEL ACOSTA AUSTIN, TEXAS CLERK

LAWRENCE DONOVAN APPELLANT

v. No. PD-0474-14

THE STATE OF TEXAS APPELLE

APPELLANT/PETITONER'S RESPONSE TO STATE'S REPLY BRIEF ON THE MERITS

TO THE COURT OF CRIMINAL APPEALS:

The State strays far from the record on appeal in footnote 2 of its reply brief. No

reference to the record is made by the State with respect to its claim that there is a second

petition for expunction pending in another court involving the same charges, nor is there a

reference to the record provided with respect to the State' s claim that it find a general denial to

that petition. The reason the State does not favor the court with record references with respect to

those allegations is that those claims are outside the record.

Respectfully Submitted,

@~·JI. DAVID L. RICH State Bar No. 16845500 3001 West 5th Street, Suite 800 Fort Worth, Texas 76107 Phone: (817) 332-5567 Fax: (817) 885-7688 daverichards@sbcglobal.net CERTIFICATE OF SERVICE

The undersigned, David Richards, certifies that that a true copy of this document has been

e-served this 301h day of December 2014, appellate division of the Tarrant County District

Attorney's Office.

DAYID L. RICH

CERTIFICATE OF COMPLIANCE

The undersigned, David Richards, certifies that this document contains 214 words.

f}fMAf / 1f_t-11M- DAYID L. RICHARDS