PD-1573-14 RECEIVED IH
COURT OF CRIMJNAL1A$elLS
MN 09 2015
IN THE COURT
OF CRIMINAL APPEALS jr_,
of texas MOel Acosta, Clerk
DAMON KENDRICK DOVE § Tt. Ct. No. 12-DCR-061181A
§
VS. § COA Case No. 14-13-00686-CR
§
THE STATE OF TEXAS § COCA Case NO. PD-1573-14
APPELLANT'S NOTICE AND OBJECTION TO THE COURT OF CRIMINA&-ED IN
APPEALS REGARDING INCOMPLETE AND INACCURATE REPORQQtJ^" fij(g§15/IINAL APPEALS
JAN 09 2015
TO THE HONORABLE COURT OF CRIMINAL APPEALS JUSTICES:
Abel Acosta, Clerk
COMES NOW, DAMON KENDRICK DOVE, pro-se, in the above styled and numbered cause
to give notice and his objection to the Court Reporter's record, because the Record
is both inaccurate and incomplete at volume-4,Pg.31-32, where the trial attorney at
tempts to make his offer of proof to the Court.
The conversation that occurred between the Trial Court Judge and defense counsel
is hard to decipher, therefore, appellant is requesting that the Court Reporter,
(Mindy Hall, No. CSR-8107) pull the audio of RR-Volume 4,Pg.31-32, and accurately
transcribe a true, correct, and complete copy of the conversation that took.-.place
during the trial proceedings.
Appellant wants this Honorable Court to be aware and understand that Appellant
can not properly appeal his conviction with these missing, lost, or destroyed inac
curate, incomplete pages, in conjunction with the record are essential to the asses
sment of the appeal process. See: T.R.A.P. 34.6(e)(2). The Court Reporter breached
her fifuciary duties by submitting an inaccurate, incomplete records to appeal at
torney, in his attempt to file a brief on Appellant's behalf, to which I object,
and I respectfully hereby request a hearing to redress the above and foregoing issues
stated above.
In addition, since the Reporter's record is inaccurate and incomplete with miss-
portions of the record, specifically the conversation between the Trial Court Judge
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and trial attorney, the appeal brief that was filed and submitted by appeal attorney
(michael Elliot) causes appellant counsel to be ineffective by default and omission
because the appellate brief was filed and submitted in the Court of Appeals based
on an inaccurate and incomplete trial court reporter's record, violating Texas Rules
of Appellate Procedure, and Appellant's Due Process rights.
Respectfully Submitted;
/K7Wvox-\,
C^
Damon Kendrick Dove, Pro-se
TDCJ No. 1880020
O.B. Ellis Unit
1697 F M 980
Huntsville, Texas 77343
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VERIFICATION OF PLEADING
I, Damon Kendrick Dove, TDCJ-No. 1880020, presently incarcerated in the Texas
Department of Criminal Justice, in Walker County, Texas, at the O.B. Ellis Unit,
do hereby vberify under penalty of perjury that the foregoing statements are true
and correct, and I have personal knowkedge of the same on that the y^- day of
January , 2015. Pursuant to Civil Practice Remedies Code Section 132.001 thru
132.003.
Respectfully Submitted,
~ \ \ •&—
MSaffion Kendrick Dove, Pro-se
TDCJ-No. 1880020
O.B. Ellis Unit
1697 F M 980
Huntsville, Texas 77343
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