Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 11/3/2015 2:37:28 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00581-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 11/3/2015 2:37:28 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS

FOR THE FOURTEENTH SUPREME JUDICIAL DISTRICT

AT HOUSTON, TEXAS

LUIS EDUARDO LARA, §

§

Appellant §

§

vs. § CASE NOS. 14-15-00581-CR

§ 14-15-00582-CR § 14-15-00583-CR §

§ TRIAL COURT NOS. 14CR2148 THE STATE OF TEXAS, § 14CR2149

§ 14CR2150 Appellee §

APPELLANT’S MOTION TO SUPPLEMENT REPORTER’S RECORD

AND ORDER BRIEF DUE THIRTY DAYS AFTER RECORD IS

SUPPLEMENTED TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF

APPEALS:

COMES NOW LUIS EDUARDO LARA, Appellant in the above-styled and

numbered cause, by his Counsel of Record, Greg Russell, and pursuant to

T EX .R.A PP .P. 34.6(g)(2), and files this Motion to Supplement Record and in

support thereof would show this Honorable Court the following:

I.

Appellant was found guilty by a jury of the offense of Sexual Assault of a

Child, Indecency with Child by Conduct and Continuous Sexual Abuse of a Child

and punishment was assessed by the Court at 15, 8 and 28 years, respectively,

Institutional Division – Texas Department of Criminal Justice.

II.

Appellant’s Brief is due on or before November 5, 2015.

III.

The Reporter’s record of Carol Castillo contains exhibits of a completely

different case, styled The State of Texas vs. Devane Salters.

IV.

The Reporter’s Record does not contain any of the exhibits from this case of

Luis Lara. During the Guilt-Innocence and Punishment phases of the trial, the

State and Appellant introduced various Exhibits (entire record). These exhibits

were not made part of the Reporter’s Record and consequently were not sent to the

court of appeals. (entire record) Appellant needs to review these exhibits as to

possible grounds of error on appeal.

V.

TRAP 34.6(g)(2) provides that the record may be supplemented with

original exhibits if request is made by the appellate court or by a party. Also, see

Pitts v. State, 916 S.W. 2d 507, 509-510. Because Appellant must inspect these

exhibits to determine possible grounds of error, Appellant hereby seeks

supplementation of this record.

RESPECTFULLY SUBMITTED, /s/ Greg Russell Greg Russell 711 59 th Street Galveston, Texas 77551 (409) 497-4743 (409) 497-4721 Fax SBN: 17411550 ATTORNEY FOR APPELLANT *4 CERTIFICATE OF SERVICE

As Attorney of Record for Appellant, I do hereby Certify that a true and correct

copy of the above and foregoing document was this date provided to the Attorney for

Appellee, by e-file service to Mr. Jack Roady, District Attorney of Galveston County

at the offices of the District Attorney of Galveston County, Texas, 600 59 th Street,

Galveston, Tx. 77551, on the 3 rd day of November 2015.

/s/ Greg Russell Attorney for Appellant CERTIFICATE OF COMPLIANCE

I do hereby certify that this brief is in compliance with rule 9.4(i) (3) of the

Texas Rules of Appellate Procedure because it is computer generated, and its

relevant portions contain 335 words.

/s/ Greg Russell Greg Russell