Quintin Ramone Lang v. State

• Court: Court of Appeals of Texas
• Decided: February 12, 2013
• Docket: 05-12-01002-CR
• Status: Published

Opinion

REED IN No. 05-12-01002-CR ~H.COURT OF APPEALS

QUINTIN LANG

COURT OF APPEALS

THE STATE OF TEXAS AT DALLAS.,. TEXAS

MOTION TO ORDER THE COURT REPORTER TO CORRECT INACCURACIES IN THE RECORD

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW Quintin Lang, Appellant in this cause, by and through his

duly appointed attorney on appeal, and requests that this Court order the court

reporter to correct Inaccuracies the record filed in this Court.

Appellant was convicted of manslaughter and sentenced to 2 years’

imprisonment. Appellant’s Brief is filed simultaneously with this Motion. This

case is not yet set for submission.

II.

During the briefing process, the undersigned attorney identified several areas

where n she believes the record is inaccurate. Specifically, these are as follows:

1) The reporter’s record as filed often refe.rences a "squid" mark. (RR4: 16, 17, 114, 142, 151,181). The undersigned attorney, based on both the context of the reference and on independent research, has formed the option that these should be "skid" marks. This is an error which the court reporter should be required to correct.

2) The reporter’s record as led often references a "yar" marks. (RR4: 142, 15 I, 152). The undersigned attorney, based on both the context of the reference and on independent research, has formed the option that these should be "tire" marks. This is an error which the court reporter should be required to correct.

3) The reporter’s record as filed twice references a Mr. Morales. This appears to be a typographical error the reporter’s record, as clear from the context that the witness being questions is talking about Mr. Morrell.

These naccuracles should be corrected to conform the reporter’s record to what

occurred in the trial court. TEX. R. APP. P. 34.6 (e).

III.

The undersigned attorney has placed four telephone calls to the court

reporter, Belinda Baraka, between January 30 and February 5, 2013, with the intent

of discussing these lnaccurac es As of the date of this motion, none of these

telephone calls have been returned.

IV.

This Motion brought so that the appellate record can be corrected to read

as accurately as possible.

WHEREFORE, Appellant requests this Court order the court reporter to

correct naccurac es the record and to file a corrected record in this Court.

2 Respectfully submitted,

Lynn Richardson A. Drew Chief Public Defender Assistant Public Defender Dallas County, Texas State Bar No. 06117800 Frank Crowley Courts Building 133 N. Riverfront Blvd., LB-2 Dallas, Texas 75207-4399 (214) 875-2360 (phone) (214) 875-2363 (fax) Kathi.Drew@dallascounty.org

CERTIFICATE OF SERVICE

I hereby certify that a true copy of the foregoing brief was served on the Dallas County Criminal District Attorney’s Office (Appellate Section), 133 N. Riverfront Blvd., B-19, 10th Floor, Dallas, Texas, 75207, by hand delivery on February 6, 2013

A. Drew