RECEIVED IN
POST TRIAL
PATRIOT CLERK OFFICE
IN THE COURT OF CRIMINAL APPEALS peg \ 3 2015
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AUSTIN,TEXAS
Deputy
W^ ' EX PARTE REVAT RENE VARA
WRIT NO. WR-75,987-04
IN THE COURT OF CRIMINAL APPEALS
CAUSE NO. 1061075-A
IN THE 208TH DISTRICT COURT
HARRIS COUNTY, TEXAS
STATE'S OBJECTIONS TO THE TRIAL COURTS
ORDER ADOPTING SPECIAL MASTER'S FINDINGS OF FACT, CONCLUSIONS OF LAW,
AND RECOMMENDATION
I.
Comes now the State of Texas, through the undersigned Assistant District
Attorney, and respectfully objects to the trial Court's Order Adopting Special
Master's Findings of Fact, Conclusions of Law, and Recommendation entered on
January 26, 2015, recommending that relief be granted in the form of a new trial.
The State respectfully disagrees with the trial court's ultimate
recommendation, and objects to the recommendation and the trial court's
findings of fact and conclusions of law which find no support in the record, or
which are plainly contrary to established law.
The State respectfully requests that the Court of Criminal Appeals find that
the trial and habeas records do not support the trial court's January 26, 2015
findings of fact and conclusions of law granting habeas relief. Additionally, the
State respectfully requests that the Court of Criminal Appeals enter an order
denying the applicant relief on all grounds urged in the instant post-conviction
habeas petition.
k>
A copy of the State's Objections to the Trial Court's Order Adopting Special
Master's Findings of Fact, Conclusions of Law and Recommendations in cause
number 1061075-A has been sent to:
Ms. Celeste Blackburn
Writ Counsel for the Applicant
333 N. Rivershire Drive
Suite 285
Houston, Texas 77304
SIGNED this 18th day of February, 2015.
Respectfully submitted,
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Sharon Y. Chu
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
713-755-6657
Texas Bar ID # 24051950