Crae Robert Pease v. State ( 2015 )

November 16, 2015
Cause No. 03-14-00512-CR
CRAE ROBERT PEASE
Appellant
v.
/RECEIVED \ THE STATE OF TEXAS
NOV 1 6 Z015 Appellee
THIRD COURT OF APPEALS.
BaKYLE"^APPELLANT'S 2nd MOTION TO SUPPLEMENT THE RECORD
AND EXTENSION OF TIME TO FILE APPEAL
TO THE HONORABLE COURT OF APPEALS:
Crae Robert Pease, Appellant, makes this Motion to Supplement the Record in
Support of Appellant's Brief, pursuant to Rule 10.1 and 10.2, Tex.R.App.Proc,
and as grounds therefore would show the Court:
I.
This cause was heard in the Travis County Court at Law No. 6 in August 11,
2014 under trial court Cause No. C-l-CR-13-220, styled The State ofTexas v. Crae
Robert Pease.
II.
While preparing his appeal, which he planned to file today, Appellant found
that there was no Reporter's Record for a hearing on July 11, 2014.
III.
The hearing was to question the validity of the information, which was
altered at the hearing on July 11, 2014. Because there are irregularities in
information which were preserved on the record of that date, Appellant requires the
Reporter's record from that date in order to complete his appeal.
This request is not meant for purposes of delay, but to verify and document
appellant issues.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court
will grant this Motion and supplement the record with the Reporter's record of July
11,2014 and extend the time to file his brief to one week after the record is filed.
Respectfully submitted,
Crae Robert Pease
6715 Skynook Drive
Austin, Texas 78745
CERTIFICATE OF CONFERENCE
On November 16, 2015, Appellant conferred with William Swaim, attorney
for Appellee, and Mr. Swaim responded that he had no objection to the extension
of time.
Crae Robert Pease
CERTIFICATE OF SERVICE
On November 16, 2015, a copy of the attached motion for extension of time
was sent by U. S. Postal Service to:
William Swaim
Travis County Attorney's Office
P.O. Box 1748
Austin, Texas 78767
Nothing in the information establishes the supposition that Travis County courts have
jurisdictionover this matter, therefore, the information is defective, the defect is of a jurisdiction
nature, and therefore must be quashed. Brown v. State, 558 S.W.2d 471 (Tex.CrApp.1977).
Respectfully submitted,
Crae Robert Pease
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the attached Motion to Quash
information was sent by e-mail and personal service on July 11, 2014 to:
Travis County Special Prosecutor
Bill Swaim
Travis County chief Prosecutor County Court at Law #6.
Randall Slagle
Nothing in the information establishes the supposition that Travis County courts have
jurisdiction over this matter, therefore, the information is defective, the defect is of a jurisdiction
nature, and therefore must be quashed. Brown v. State, 558 S.W.2d 471 (Tex.Cr.App.1977).
Respectfully submitted,
Crae Robert Pease
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the attached Motion to Quash
information was sent by e-mail and personal service on July 11,2014 to:
Travis County Special Prosecutor
Bill Swaim
Travis County chief Prosecutor County Court at Law #6.
Randall Slagle ._.—--