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