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,
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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.
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DAYID L. RICHARDS