Tocarra Lockett A/K/A Tocarra McKind v. State

Opinion

ACCEPTED

12-13-00357-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

4/7/2015 3:32:57 PM

CATHY LUSK

CLERK

IN THE COURT OF APPEALS FOR THE TWELFTH DISTRICT

FILED IN

OF TEXAS 12th COURT OF APPEALS TYLER, TEXAS

4/7/2015 3:32:57 PM

TOCARRA McKIND aka CATHY S. LUSK Clerk

TOCARRA LOCKETT, § APPELLANT § §

v. § No. 12-13-00357-CR §

THE STATE OF TEXAS, § APPELLEE §

STATE'S RESPONSE TOAPPELLANT'S MOTION FOR BOND FOLLOWING REVERSAL OF CONVICTION PURSUANT TO TEX. CODE CRIM. PROC.

ART. 44.04(h)

FROM THE 420th DISTRICT COURT NACOGDOCHESCOUNTY,TEXAS

TRIAL CAUSE NUMBER F1320229 THE HONORABLE EDWIN KLEIN, JUDGE PRESIDING

CRISTIN LANE Assistant District Attorney Nacogdoches County, Texas

101 West Main Street Nacogdoches, Texas 75961 Phone:(936)560-7766 FAX: (936) 560-6036 State Bar No. 24074573

STATE'S RESPOSNE TO APPELLANT'S MOTION FOR BOND FOLLOWING REVERSAL OF CONVICTION PURSUANT TO TEX. CODE CRIM. PROC.

ART. 44.04(h)

TO THE HONORABLE JUDGES OF THE TWELFTH COURT OF APPEALS:

COMES NOW, the State of Texas, appellee, by and through this attorney of record,

Cristin Lane, in response to the motion requesting the Court release Appellant, Tocarra

McKind, aka, Toccara Lockett on reasonable bail, that bail be set at $2500.00, and that

the Trial Court be ordered to bench warrant Appellant to Nacogdoches County forthwith

for a determination concerning the approval of sureties on the bail.

STATEMENT OF FACTS

1. The State of Texas believes there to be no discrepancy in the Statement of

Facts delineated in Appellant's Motion for Bond Following Reversal of

Conviction.

ARGUMENT AND AUTHORITIES

1. The State of Texas believes the argument and authorities quoted in support of

Appellant's Motion for Bond Following Reversal of Conviction to be

controlling law, and finds no legal argument to undercut that authority.

PRAYER

WHEREFORE, for the reasons stated above, the State of Texas prays the Court

of Appeals follow the recommendation of the Appellant as stated in Appellant's Motion

for Bond Following Reversal of Conviction.

Respectfully submitted, Cristin Lane

fl& Assistant District Attorney

Nacogdoches County, Texas 101 West Main Street Nacogdoches, Texas 75961 Phone: (936) 560-7766 FAX: (936) 560-6036 State Bar No. 24074573

CERTIFICATE OF SERVICE

A true copy of the State's brief has been served via FAX/ certified mail/

the 7th day of April 2015. lM= hand delivery/ electronic delivery to counsel for Appellant, Seth Johnson, on this, ~-<

Cristin Lane Assistant Criminal District Attorney