### No oral argument required
No. 13-08168-3

In The COURT OF APPEALS FOR THE THIRD DISTRICT OF TEXAS



### STATE OF TEXAS,



### Plaintiff-Appellee

v. GAYLEEN S. TODD 

### Defendant- Appellant.



### On Direct Appeal from The COUNTY COURT AT LAW 

## OF (public) RECORD ^RECEIVED\ 

# IN THE CITY OF GEORGETOWN APR282015 Trial Case No. l VJiFFRfojSy
TODD'S BRIEF Gayleen S. Todd 2116 JuniperTrail Round Rock, Texas 78664 

### 1 Only cases have numbers. There being no charging instrument(s) filed, much less served, there isno case here by any number. Areference number used by the county court is03-14-00386.Identity of Parties and Councel Appellant Appellee GAYLEEN S. TODD STATE OF TEXAS 

### 2116 Juniper Trail Office of the Attorney Round Rock, Texas 78664 Williamson Co. Justice Center In the City of Georgetown
Assertion ofRights 

### Gayleen Todd (Todd1) asserts all her unalienable rights, privileges, and immunities at Natural Law, Common Law, and Maritime Law, and all her commercial rights relevant to " this state". Objection to Non-judicial Decision Making

Todd objects to and does not consent to any assignment or any referral of this 

### case, in any part, to any decision-maker other than a duly elected or properly appointed judicial officer exercising full authority of an appellate court judge/ justice and who has an active and current oath of office on file. CF. Gonzales f Ifthe parties consent") (Construing 28 U.S.C. 636(b). Objection to use of Private Law

Todd objects to the use of unpublished cases. A cite to "WL" and "Lexis" is a 

### reference to materials not publicly accessible. For such references to even begin to be meaningful, a full copy of the opinion for each "WL" or "Lexis" reference must be attached.

Table of contents TODD'S BRIEF i Identity of Parties and Councel ii

Assertion of rights ii Appellant's Brief (Todd) ii
No Notice. No Commercial nexusObjection to Non-judicial Decision Making ii Objection to use of Private Law ii Index of Authorities v Statement of Case x

Nature of the Case x Course of Proceedings x Present Trial Court Disposition x No Oral Argument Requested xi Issues Presented xi Statement of Facts 1

Record references 1 Procedure 1 Merits 3 Summary of the Argument 4

No subject matter jurisdiction 4 No personal jurisdiction 4 No evidence against Todd 4 "judgment" is void 5 Argument 5 Appellant's Brief (Todd) iii
No Notice. No Commercial nexusPoint 1: What was Todd's plea? -clerical error 5 Point 2: Procedure to correct record is what? 5 

### Point 3: Did the trial court compel Todd's consent? 5 Compelled consent generally 5
Compelled consent during trial 6 

### The court totally relieved STATE of it's burden of proof 8 Point4: Did the trial court violate Todd's right to a fair trial? (Parti) 8 Denial of right to a fair trial 8 The trial totally disallowed Todd's defense 9 

### Point 5: Did the trial court violate Todd's right to a fair trial? (Part 2) 9 Denial of access 9 

### Point 6: Did the trial court violate Todd's right to travel? 10 The right to travel, generally 10 There's no practical or legal difference between in-TER- and in-TRA-state ...10 travel in "this state" 11 

### Point 7: Did the trial court violate Todd's right (not) to contract? 11 

### Point 8: Did the trial court violate Todd's right (not) to engage in commerce?12 Point 9: Does the trial court have personal jurisdiction? 13 Appellant's Brief (Todd) iv No Notice. No Commercial nexus

### Overview: The systemic problems regarding notice 13 Notice requires both filing and serving the paperwork 13 Notice used to require filing and serving two documents 14 Without both of those documents, there was no notice 14

The "The lack of attorney signature" problem 14 

### No pleading filed? — no Notice 14 No pleading served? — no Notice 15 In sum, no pleading? — no Notice 15 The "lack of witness statement" problem 15 In sum, no complaint and no pleading? — no Notice 15 Point 10: How is it fair that the trial court had two attorneys prosecuting? 15 Point 11: What law did the trial court act on by refusing to answer the jurors' question during their deliberations? 16 Request for Releif 17 Certificate of Service Appendix Contents 20

Index ofAuthorities Cases 

### Alexander v. State, 240 S.W. 3D 72 (Tex. App. - Austin 2007 no pet.) Anderson v. Liberty Lobby Inc., All U.S. 242 (1986) Appellant's Brief (Todd) v No Notice. No Commercial nexusAptheker v. Secretary ofState, 378 U.S. 500 (1964) Arizona v. Johnson, 129 S. Ct. 781 (2009) Arnold v. United States, 544 U.S. 1058 (May 31, 2005) Att Gen. of NY v. Soto-Lopez, Alb U.S. 898 (1986) Bailey v. State, 15 S.W. 3d 622 (Tex. App. - Dallas 2000, no pet.) Ballard v. Comm'r; 544 U.S. 40 (2005) Bates v. State Bar ofArizona; 433 U.S. 350 (1977) Boddie v. Connecticut; 401 U.S. 371 (1971) Burger King Corp. v. Rudzewicz; All U.S. 462 (1985) Christopher v. Harbury; 536 U.S. 403 (2002) Computize, Inc. v. NHS Comm. Group, Inc.; 992 S.W. 2d 608 (Tex. App.

- Texarkana (1999, no pet.) Davis v. State; 203 S.W. 3d 845 (Tex. Crim. App. 2006) Del Dev. Corp. v. Best Indus. Unif. Supply Co., Inc.,; 1A3 S.W. 2D 302 (Tex. 

### App.-Houston [14th Dist.] 1987, (writ, denied) Devenpeck v. Alford 543 U.S. 146 125 S. Ct. 588 (2004) Dunn v. Blumstein, 405 U.S. 330 (1972) Edwards v. California 314 U.S. 160 (1941) Escobedo v. Illinois 378 U.S. 478 (1964) Ex Parte Smythe 116 Tex. Crim. 146, 28 S.W 2D 161 (Tex. Crim. App. 1930) Garcetti v. Ceballos 547 U.S. 410 (2006) Globe Leasing, Inc. v. Engine Supply and Mach Serv., A31 S.W. 2D 43 (Tex. 

### Civ. App. -Houston [1st Dist] 1969 no wrti) Gonzalez v. United States 553 U.S. 242 (12 May 2008) Goodman v. Luken Steel co. 482 U.S. 656 (1987) 

### Graham v. Lappin 255 F. 3d 906 (7th Cir. 2001) Griffin v. Breckenridge 403 U.S. 88 (1971) Griswold v. Connecticut 381 U.S. 479 (1965) Hamdi v. Rumsfeld 542 U.S. 507 (2004) Heiner v. Donnan 285 U.S. 312 (1932) Herring v. United States 129 S. Ct. 695 (2009) Hiibel v. Sixth Judicial Dist. Court ofNev., Humboldt County 542 U.S. 177, 124 S. Ct. 2451 (2004) Holmes v. State 323 S.W. 3d 163 (Tex. Crim. App. 2009) Illinois v. Caballes 543 U.S. 405, 125 S. Ct. 834 (2005) In Re Winship 397 U.S. 133 (1955) Jones v. Helmes 452 U.S. 412 (1981) 

## Jordan v. State 51 Tex. Crim. 531, 103 S.W. 633 (Tex. Crim. App. 1907) Appellant's Brief (Todd) vi
No Notice. No Commercial nexus.Kent v. Dulles 357 U.S. 116 (1958) 

### Kuntoplast ofAm., Inc. v. Formosa Plastics Corp. USA, 937 S.W. 2d 455 (Tex. 1996) Lloyd v. Alexander 5 U.S. (1 Cranch) 365 (1803) Marsh USA Inc. v. Cook 354 S.W. 3d 764 (Tex. 2011) Miranda v. Arizona 384 U.S. 436 (1966) 

### Moore v. Elektro-Mobil Technik GmbH, 874 S.W 2d 324 (tex. App. - El Paso 1994, writ denied) Mullaney v. Wilbur 421 U.S. 684 (1975) Murphy Bros. Inc. v. Michetti Pipe Stringing, Inc. 526 U.S. 344 (1999) 

### Ohralik v. Ohio State Bar Assn. 436 U.S. 447 (1978) Plumbers' Union v. Borden 373 U.S. 690 (1963) Pollock v. Farmers' Loan and Trust Co. 157 U.S. 429 (1895) (Pollock I) Portier v. State 68 S.W 3D 657 (Tex. Crim. App. 2002) Rothgery v. Gillespie County, Texas 554 U.S. 191 (2008) Rowland v. California Men's Colony 506 U.S. 194 (1993) Safford Unified Sch. Dist. No.l v. Redding 129 S. Ct. 2633 (2009) Scott v. Harris 550 U.S. 372 (2007) Shapiro v. Thompson 394 U.S. 618, 89 S. Ct. 1322 (1969) Smith v. O'Grady 312 U.S. 329 (1941) 

### Standard Oil Co. ofNew Jersey v. United States 221 U.S. 1 (1910) Storrie v. Cortes 90 Tex. 283, 38 S.W. 154 (1896) Terry v. Ohio 392 U.S. 1 (1968) 

### Tex. Dept. ofParks and Wildlife v. Miranda 133 S.W. 3d 217 (Tex. 2004) United States v. Booker 543 U.S. 220 (2005) 

### United States v. Brown 117 F. 3d 471 (11th Cir. 1997) United States v. Diebold 369 U.S. 654 (1962) United States v. Guest 383 U.S. 745 (1966) 

### Valle v. State 109 S.W 3D 500 (Tex. Crim. App. 2003) Virginia v. Moore 553 U.S. 164, 128 S. Ct. 1598 (2008) 

### Webb v. State 766 S.W. 2D 236 (Tex. Crim. App. 1989) Wiley v. State 1A S.W. 3D 399 (Tex. Crim. App. 2002) Zemel v. Rusk 381 U.S. 1 (1965) Zobel v. Williams 457 U.S. 55 (1982)
Appellant's Brief (Todd) vii

No Notice. No Commercial nexus.Statutes 28 U.S.C. 636(a), (c) 28 U.S.C. 636(b) Tex Gov't Code Ann. 30.00024(a) (Thomson/West Supp. 2010) Tex. Gov't Code Ann. 30.00027(b) (1) (Thomson/West 2012)

Rules of Criminal Procedure Tex. Crim. Proc. Code Ann. art 2.04 (Thomson/West 2011) ("Art. 2.04") Art. 2.05 Art. 21.20 Art. 21.22 Art. 25.04 Art. 27.01 Art. 45.01 (repealed, eff. Sept. 1999) Art. 45.018(b) Art. 45.019

Rules of Civil Procedure Fed. R. Civ. P. 8(c) Fed. R. Civ. P. 8(c)(1) Tex. R. Civ. P. 94 Tex. R. Civ. P. 316 Tex. R. Civ. P. 329b(f)
Rules ofAppellate Procedure Tex. R. App. P. 38.6
Appellant's Brief (Todd) viii
No Notice. No Commercial nexus.Treatises 1 Page, The Law of Wills 5.7, 5.11 (rev. 2003) Amy Morris Hess, George Gleason Bogert & George Taylor Bogert, The Law of 

### Trusts and Trustees_ (Supp. 2011) ("Bogert") Bogert 42 (Supp. 2011) Bogert 44 (Supp. 2011) Professional Responsibility 

### ABA Model Rules of Prof'1 Conduct R. 3.7 (2002) ("ABA Rule 3.7") Tex. Disciplinary Rs. Prof'1 Conduct 3.08, 5.05, reprinted in 3A Tex Gov't Code Ann. pp. 296-97, 327, (title 2 subtitle G. app. A (after 84) (Thomson/ West 2011) (Tex. State Bar R. art X 9)

Appellant's Brief (Todd) ix

No Notice. No Commercial nexus.Statement of the Case Nature of the Case 

### "Civil" due to no Notice and no "actual grievance" Fail to maintain proof of financial responsibility
Course of Proceedings


### Todd's Special Appearance and Motion to Dismiss was supposed to be heard before the trial court on the day of trial. Instead, each motion was overruled 

### before it could even be said. Todd Formally Declined to Plea, due to the lack of Notice. Todd was continually denied the right to present case law and evidence that would have proved the STATE to have no standing, no jurisdiction, and no case against Todd.
Present Trial Court Disposition


### Todd stands "convicted" of failure to maintain proof of financial responsibility. Fine is $220.

Appellant's Brief (Todd) xNo Notice. No Commercial nexus No Oral Argument Requested Oral argument is not expected to aid in the resolution of these issues.

Issues Presented Point 1: What was Todd's plea?

- clerical error Point 2: Procedure after reformation is what? Point 3: Did the trial court compel Todd's consent? Point 4: Did the trial court violate Todd's right to a fair trial? (part 1) Point 5: Did the trial court violate Todd's right to a fair trial? (part 2) Point 6: Did the trial court violate Todd's right to travel? Point 7: Did the trial court violate Todd's right (not) to contract? Point 8: Did the trial court violate Todd's right (not) to engage in commerce? Point 9: Does the trial court have personal jurisdiction? Point 10: How is it fair that the trial court had two attorneys prosecuting? 

### Point 11: What "law" did the trial court act on by refusing to answer the jurors' question during their deliberation?

Appellant's Brief (Todd) xi
No Notice. No Commercial nexus.Statement of Facts

Procedure 

### Due to "no Notice" This is a non-case: hence civil. To talk procedural facts is to talk procedural rules so as to identify the relevant procedural facts. The "case" was opened not with a complaint but with a "citation". 

### Todd appeared specially, Sp. App., objecting to the trial court's subject matter, 

### jurisdiction, personal jurisdiction, and venue. There being no direct ruling, the Sp. App. was denied by operation of law. 

### Formal Declination to Plea. STATE never gave Todd any Notice of any charge against her. Todd never pled: hence never waived Notice: Hence no response


### was ever due. See Art 45.018(b). Not only was no response due, but the trial 

### court never had jurisdiction. Not even to set a trial. Even per STATE'S hideously tortured concept of "availability" of a "complaint", no "complaint" was even "available". 

### Since a ruling of any type, responsive to the Sp. App. has got to constitute "any proceeding", cf Rothgery (arraignment is a proceeding), it follows, that as of that date June 2, 2014, STATE'S deadline for timely service came and went. Arraignment didn't happen until the date of trial, and even then, there was still 

### Appellant's Brief (Todd) T
No Notice. No Commercial nexus.No Notice to Todd of any charge against her in compliance with Art. 45.018(b). 

### STATE never served any charging instrument on Todd. Period. Much less a day 

### before "any [ie. the first] proceeding". If STATE actually believed it's DueProcess-defiant "availability" theory, why was an unfilestamped copy of the alleged "complaint" handed to Todd at all, even on the day of trial? STATE was 

### silent when confronted by the fact that a ticket alone is not a charging instrument. That silence is proof enough what STATE is well aware of. 

### By pretending the alleged complaint was available, STATE confessed not only "no Service per Art. 45.018(b)" but also no intent to Serve, which is attitudinally 

### straight out of Art. 25.04, STATE is judicially confessing the total change in what constitutes Notice now that Art. 45.01 has been repealed. STATE loses either way: there was no Service of any (type of) charging instrument. Yet if we're still under Art, 45.018(b), then the instrument to be Served is merely a "complaint". But if we're now, (since 1999) UNDER Art. 25.04, Then STATE must Serve not only a "Complaint" but also an "Information". There is no Information to be found anywhere, including the Record and STATE most certainly didn't Serve any "Information" at any time. The trial court ruled that Todd not be allowed to object to the commercial 

### terms identified in her Standing Evidentiary Objections. The sum and substance Appellant's Brief (Todd) 2
No Notice. No Commercial nexus

### of that ruling is that it effectively prohibited Todd from being able to defend 

### herself in this matter. Specifically, that ruling prevented Todd from objecting to the key commercial terms in "transportation" cases: "transportation", "vehicle", "drive" (in all of its forms), "motor vehicle", and "operate" (in all of its forms). Since STATE had no (and for this type of case never has) evidence of "transportation", i.e., a bill of lading or a passenger manifest, the sole mechanism on which STATE depends is consent to the commercial terms.
Merits 

### CITY acted at all times as STATE'S agent. In such capacity, CITY issued Todd the fail to maintain financial responsibility ticket in dispute. The only people liable for fail to maintain financial responsibility are those engaged in transportation or those involved in an accident or some other form of harm (bodily or otherwise) to another person or property. It matters then that there 

### was no harm of any kind and that Todd was never engaged in "transportation". 

### Specifically she was never (1) removing people and/or property (2) from here to there (3) for profit or hire. (4) under any choice of law, including that of "this 

### state". CITY/STATE provided no evidence on any of these elements of "transportation". 

### Since STATE depends 100% not on any actual evidence of "transportation" Appellant's Brief 3
No Notice. No Commercial nexusbut rather on the scam nature of commercial consent to the semantics of the 

### commercial terms ofart, it's instantly relevant that the trial court totally prohibited Todd from objecting at a critical time. In sum, on the merits, the trial court compelled Todd to consent to being in "transportation" Summary of the Argument
No Subject Matter Jurisdiction 

### STATE never had an "actual grievance" because Todd was never engaged in "transportation". Due to the absence of both "transportation" and Notice, this is a non-case; hence civil.
No Personal Jurisdiction 

### CITY/STATE never Served Todd with any charging instrument "at least a day 

### before any proceeding" Art. 45.018(b). Moreover, given the appeal of Art. 45.01 (effective 1999), Todd very strongly doubts that "complaint only" cases are still lawful at all, and there certainly was no "information" Served. No Evidence Against Todd 

### There is no evidence that Todd (A) removed anything or anyone, (B) from 

### here to there, (C ) for profit or hire (D) under any choice of law including "this
state". Appellant's Brief (Todd) 4
No Notice. No Commercial nexus."Judgment" is Void The "judgment" is void. As STATE'S agent, CITY should be ordered to refund Todd's cost of impounding her car and strike the so-called ticket off her record. Argument
Point 1: What was Todd's Plea? -clerical error 

### Todd never entered a plea. How could she? She was never Served with 

### anything to which a responsive plea was due. The court entered a plea of Not Guilty on Todd's behalf. Thus, Todd never waived Notice. If Todd's objection

• 

### to the court's charge wasn't carried forward into the document, Todd objects to the document. Point 2: Procedure to Correct Record is What? 

### Cy Tex. Rs. Civ. P. 316 (clerical errors) 329b(f) (timing of correction of clerical errors). Since this court may actually have power to reform the county court's documents, Todd is not submitting a Motion for Abatement. Cf. Alexander, 240 

### S.W. 3D at 74 (county criminal [i.e. appellate] court may affirm, reverse, or reform the trial court's judgment) (citing Gov't Code 30.00024 (a)). Point3: Did the Trial Court Compel Todd's Consent? Compelled consent generally Appellant's Brief (Todd) f

No Notice. No Commercial nexusConsent cannot be compelled, period. Rudzewicz (jurisdiction doesn't flow from fraud, undue influence, or overwhelming bargaining power); Fed. R. Civ. P. 8(c); Tex. R. Civ. P. 94; Ballard (local rules don't justify (criminal) Due Process violations); 636(a). (c) ("by consent only"): Gonzales ("If the parties consent") (construing 636(b)). Compelled consent is the exact antithesis of the very soul of "this state". 

### The coercive environment vitiates the very "evidence" it purports to create. Ohralik (addressing coercion specifically engaged by the legal profession). Bates (addressing coercion specifically engaged by the legal profession) Escobedo (coerced confession is not evidence): Miranda (same): 1 page 5,7, 15.11 (coerced will is not evidence): Bogert42 at 434, 44 at 452 and n.16 (coerced trust is not 

### evidence): Pollock I, 157 U.S. At 553-54 (1st of opinion) (non consent by even 1 

### beneficiary prevents amendment to trust agreement: Arnold (vacated per Booker) ("evidence" (and never-before-heard-of-charges) not presented at trial and not agreed to at sentencing is (are) inadmissible for sentencing). Compelled Consent During Trial 

### Given that "transportation" is a privileged, commercial activity, for which a "license" is required, it follows that such line of conduct is entered into one and only one way: purely voluntarily. Appellant's Brief (Todd) 6No Notice. No Commercial nexus 

### Evidence of transportation typically includes a passenger manifest or a bill of lading. There never was any such evidence in any way associated with this case. In matters that don't involve big rigs or buses or vans or taxis, CITY/STATE 

### goes to trial knowing full good and well that there are no people or goods being moved from one point to another for profit or hire (under any choice of law). In other words CITY/STATE knows full good and well that there's no 

### "transportation" at issue. By what mechanism, what shinanigan, what scam, then, does STATE rely on to "prove" "transportation"? The answer is this: The defendant's silence (i.e. consent) in response to questions using, thus presuming 

### satisfaction of, the key commercial term, which is "transportation". In other words STATE'S "transportation" position is 100% bluff, 100% dependent on the legal ignorance (or incompetence) of the defendant. STATE moves forward in 

### these matters in 100%) bad faith, and, here, the trial court subtly encouraged it. In short "the" defense to "transportation" non-cases, is consent to the commercial terms, by which objection the term "transportation" is never 

### consented to. By the whole preventing Todd from objecting to the very terms 

### through which "consent" is clandestinely acquired in such cases, the municipal court has not only compelled Todd's consent but also has violated Todd's access 

### to the court, right to a fair trial, and right (not) to contract. 

### Appellant's Brief (Todd) ]No Notice. No Commercial nexus. 

### The matters to which Todd objected aren't just matters of evidence. They're also matters that go to the very heart of her defense. See her Sp. App. where the defendant doesn't consent to being regulated as one engaged in "transportation". CITY/STATE never has standing: hense the court never has subject matter jurisdiction. Thus it's not just a matter of evidence on the merits 

### but also a matter of evidence on the threshold issue ofjurisdiction. See Todd's Sp. App. The court totally relieved STATE of it's burden of proof By compelling Todd's consent, the court relieved STATE of it's burden. Cf. 

### Scott (summary judgment, video of car chase relevant), (citing Diebold, 369 U.S. at 655: Anderson, All U.S. at 255) (summary judgment presumptions are against movant). Mullany (citing In re Winship) (to relieve plaintiff of burden is to violate Due Process.): Heiner. 

### Point4: Did the Trial court deny Toddfs Right to a Fair Trial? (parti) Denial of Right to Fair Trial (part 1) 

### Anytime the defendant is flat out prevented from putting on her defense, the right to a fair trial is violated. In most cases it's a matter of evidence exclusion Cf, e. g. Holmes 323 S.W. 3D at 169-70 (prohibited from cross exam of STATE'S expert): Davis (evidence): Valle, 109 S.W. 3d at 506: Webb 766 S.W. 2d at 244 Appellant's Brief (Todd) 8No Notice. No Commercial nexus 

### (exclusion of witness). Of course the commonly cited case is Potier. The analysis 

### with language that is the closest to the concept at issue here is Wiley, 1A S.W. 3d at 405 ("In other words the erroneous ruling goes to the heart of the 

### defense"). Todd was in fact prevented from defending herself: hence, she was denied a fair trial. The Trial Court Totally Disallowed Todd's Defense 

### The trial court completely prevented Todd from defending herself and 

### basically compelled Todd to consent to "everything". By not being allowed to object to the key commercial terms on which the consent-based "transportation"
scam depends, Todd was compelled to consent to being a party willfully and knowingly engaging in "transportation" activity: hence, also to the matters for 

### which CITY/STATE carries the burden of proof, e.g., standing (proving the 

### existence of an "actual grievance"): thus, ultimately, to the court's subject matter jurisdiction. In short, the trial court violated Todd's right to a fair trial. Point5: Did the Trial Court Deny Todd's Right to a Fair Trial (part 2)
Denial ofAccessible 

### See Motion for New Trial. The prosecutors were allowed to access all kinds of materials via the computer during the trial. Todd was not allowed to access 

### anything by computer and had to rely on the printed materials. That's a Appellant's Brief (Todd) 9No Notice. No Commercial nexus. flagrantly unfair trial environment. Cf. Hamdi (denial of access and of 

### opportunity to be heard): Boddie (denial of access): Harbury (same). Point 6: Did the Trial Court Violate Todd's Right to Travel? The Right to Travel, generally 

### Post-1913. Edwards (right to "transport" indigent people in interstate commerce): Kent (even communists have a right to travel (passport)): Aptheker (travel at home and abroad is a right guaranteed to a citizen, even to communists.): Zemel (citing Kent, Aptheker) Guest (241 broad enough to cover 

### right to travel from state to state). Post 1965 (case start dates). Griffin (right to interstate travel: Dunn (clarifying Shapiro "In any classification which serves to 

### penalize the exercise of that right, unless shown to be necessary to promote a compelling governmental interest, is unconstitutional." 394 U.S. At 634): Jones v. 

### Helmes (right to travel is "interstate" in nature); Zobel (concuring opinions provide context for right to travel cases); Soto-Lopez; (sometimes "right to travel" may be better labled as "right to migrate"). There's no practical or legal difference between in-TER-state and in-TRAstate travel in "this state".

There are no States. Post-1965. Cf. Graham (despite Art. Ill 2, Art. IV, 2, 

### and the Sixth Amendment, Colorado (transferee) trial court had jurisdiction 

### Appellant's Brief (Todd) H)"
No Notice. No Commercial nexusover (criminal) Murrah Building bombing cases which arose in Oklahoma; to challenge the transferee court's jurisdiction by arguing the "constitution" was (1) frivolous, (2) without merit, (3) of no authority, and (4) ludicrous. Post 1913 See also U.S. Const. Amend. 17. The 17 Amendment superceded the original language as to how "senators" are chosen. Originally, the senate was the State's legislative body, which offices were filled by action of each State. States haven't 

### selected "their" representative for "their" legislative body since 1913, meaning States haven't existed for all kinds of legal purposes since 1913. 

### There is a theoretical difference between in-TER-state and in-TRA-state activity. The "right to travel" is recognized in, and it's associated with the notion of 

### in-TER-state travel. However given that there is only one "state" i.e. "this state," "everything" is in-TRA-state. Thus either there are no in-TER-state theories that 

### apply at any time for any reason, which means that there's no in-TER-state right to travel, any more, or that in-TER-state "right to travel" permeates the entirety of "this state". Point 7: Did the Trial Court Violate Todd's Right (not) to contract? 

### Even if what we're talking about is an in-TRA-state matter, hence nothing for which the in-TER-state "right to travel" is relevant, we're still talking about "transportation", which is engaged one and only one way: "voluntarily". No one 

### Appellant's Brief(Todd) ITNo Notice. No Commercial nexus 

### may be "compelled to agree" to engage in "transportation" activity. Standard Oil Co. (anti-trust context, right to carry on trade or business is recognized in context of right to contract); Goodman (right to contract in race 

### discrimination context); Plumbers' Union (union tortiously interfered with right to contract). See also Fed. R. Civ. P 8(c) 1 (affirmative defense of duress); Tex. R. Civ. P. 94. CCA: Jordan, 51 Tex. Crim. at 532. 103 S.W. at 634. Ex Parte Smythe, 116 Tex. Crim. at 149. 28 S.W. 2d at 163 Tex. S. Ct.; Storrie 90 Tex. at 287, 38 S.W. at 156; Marsh USA Inc. Todd has a right not to contract, which right she has asserted from the instant this started. By asserting her objections to the key commercial terms on which this "transportation" scam so heavily depends, via her Sp. App. and then via her Standing Evidentiary Objections, she was asserting her right not to contract 

### By overruling her Sp. App. and by bulldozing her Standing Evidentiary Objections, the trial court disallowed her objections, effectively compelling Todd 

### to agree that she was engaged in "transportation", where the reality is that she
never was. Thus, the trial court has violated Todd's right not to contract. Point 8: Did the Trial Court Violate Todd's Right (not) to Engage in Commerce? See e.g. Griswold (to outlaw contraceptives is to compel married women to Appellant's Brief (Todd) 12No Notice. No Commercial nexus 

### use "marriage license" to make babies for STATE) (i.e. even those with licenses cannot be compelled to use them.) 

### STATE cannot compel even those with "licenses" to engage in that line of commerce for which that "license" exists. A cab "driver" or "operator", a bus 

### "driver" or "operator" can never be prevented from also just being a "traveler". Just because one has a "license" it absolutely, positively, no way under the heavens means that s/he's actually using it at any particular time. Thus, those who are not in those professional lines of "transportation" are never "drivers" or 

### "operators" by any means other than STATE'S skullduggery in the legal 

### mechanism of clandestine consent. To disallow Todd's objections is to compel Todd into "transportation". 

### Point 9: Does the trial court have personal jurisdiction? Overview: The systemic problems regarding Notice. 

### For there to be personal jurisdiction, there must first be proper Notice. Notice requires both filing and serving the paperwork 

### Murphy Bros. Inc. (timing and sequence matter regarding filing and serving) 

### Lloyd, 5 U.S. At 366 ("A citation not served is as no citation"). Clearly "citations" and "complaints" Art. 45.018(b), are two entirely different things 

### All cases whether civil or criminal, have the same generic requirements. Cf Appellant's Brief (Todd) \3No Notice. No Commercial nexus. 

### O'Grady. See also United States v. Brown ("real Notice" habeas context). And there is to date, no Notice: hence, this is a non-case i.e. civil. Notice used to require filing and serving two documents. 

### Before about 1965, Notice for misdemeanor cases required the filing and serving of two documents: (1) a sworn statement ("complaint") and (2) a pleading, i.e. the Information. See Arts. 2.04, 2.05, 21.20, 21.21, 21.22, 27.01. Without both of these documents, there was no Notice.

THE LACK OF ATTORNEY SIGNATURE PROBLEM 

### To examine into the pleading first, STATE is, in actuality, a corporate entity,
a commercial enterprise, doing business in "this state" via the benefit of a tax exemption certificate. No artificial entity may appear in court without authorized 

### signature. For a misdemeanor case that authorized signature exists if there's a pleading. For a misdemeanor, the pleading is the Information. No pleading filed- no Notice [Tex. Const. Art. 5, 12]; Arts. 2.04, 21.20, 21.21, 21.22, 27.01: Rowland 506 

### U.S. at 201-03 (all artificial entities must have counsel-federal); Tex. R. Civ. P. 7 (corporations must have counsel

- state); Kuntoplast ofAm. Inc., (same) 

### Computize Inc. (same) Moore; (same) Dell Dev. Corp. (same) Globe Leasing Inc. A31 S.W. 2D at 45-46 (same); ABA Model Rules of Prof'L Conduct R 3.7 Appellant's Brief (Todd) 14No Notice. No Commercial nexus. 

### (material witness can't also be attorney of Record); Tex Disciplinary Rs. Prof1 Conduct 3.08, 5.05 (same, plus facilitating unauthorized practice); Garcetti v. 

### Ceballos (ethics still matter; "whistleblower" lawyer who testifies against client is fortunate still to have license, much less job); Tex. Dept. ofParks and Wildlife v. Miranda (standing, burden on plaintiff, requires "actual grievance"

- state). No pleading served? - no Notice A pleading has meaning sometime after it's been filed, not before. See Murphy Bros. Inc. A pleading has meaning sometime after it's been served, not before. Lloyd, 5 U.S. At 366 ("A citation not served is as no citation."). In sum, no pleading? No Notice Thus without a pleading, there simply was no Notice, thus no case. 

### The Lack of witness statement problem No "administrative citation" ("ticket") has ever been a "complaint". A "complaint" is a sworn statement. See Arts. 2.04, 21.22, 45.018 and 45.019 In sum, no complaint and no pleading?

- No Notice 

### Thus, it used to be that without the filing and serving of both a "complaint" and an Information, there simply was no Notice. 

### Point 10: How is it fair that the trial court had two attorneys prosecuting? 

### Appellant's Brief (Todd) 1?No Notice. No Commercial nexus. 

### The trial court had two prosecuting attorneys conspiring against Todd. Todd was not allowed to have representation other than herself. The trial court was in direct violation of Tex. Crim. Code of Proc. Art. 45.020(b). Not more than one 

### council is allowed to conduct either the prosecution or defense. Todd-0. STATE -2 Fair? Impartial? Legal? Not. 

### Point 11: What law did the trial court act on when refusing to answer the jurors' question? 

### The jury asked this question during deliberation, "Is there a legal procedure allowing the entry of a license plate into a database for the purpose of 

### identifying whether a car has insurance?" To which the Judge replied, "The court under the law, is not permitted to answer the question you presented." Todd demands to know what "law" allows or disallows the trial court to answer a jury's question? It all could have been over then and there. In application of these points 

### There was never any "transportation" at issue, which greatly explains why there was never any evidence of "transportation". Since Todd was not engaged in "transportation", there was no "vehicle", no "driver", no "motor vehicle", and


### no "operator". Therefore there was never any authority to issue any ticket. For the trial court to disallow Todd's objections to these terms, was for the trial 

### Appellant's Brief(Todd) 16"No Notice. No Commercial nexus. 

### court to prevent, completely, Todd's defense, and to compel consent, and to deny 

### access, and to violate Todd's right to a fair trial. This trial was in no way fair or impartial. There were two licensed prosecuting attorneys and a judge who would not listen to, or accept any evidence of, or take judicial notice of, 

### anything that even had a chance of causing reasonable doubt, all conspiring Todd in order to strip her of her rights and maliciously, knowingly, and illegally condemn her in the eyes of the jury. Request for Relief Wherefore, premises considered, Todd requests relief as follows:
* Declare that Todd's right of Due Process has been violated:
* Reform the clerical errors that the county court refused to correct (points

* Declare that the repeal of Art. 45.01 materially changed the procedures



### (point 9) and also declare that Notice for all misdemeanor matters requires both a "Complaint" and an Information.
* Declare that for municipal courts of record, the period of "one day" for Notice, as found in Art. 45.018(b), is unconscionable.
* If Art. 45.018(b) still applies, declare that a "proceeding" includes ruling
on a pre-trial motion, setting a trial date, and conducting a trial. 

## Appellant's Brief (Todd) 17No Notice. No Commercial nexus. 

### * Strike Art. 25.04 which purports to relieve STATE of it's burden to 

### both file and Serve it's original pleading(s), as repugnant to Due Process. 

### * Declare that STATE'S Notice is facially invalid for proceedings in municipal courts of Record where there's (A) no attorney's signature, and (B) no address provided for Service of the defendants documents. 

### * Having settled what Notice now requires, Vacate the "judgment" as void 

### for want of personal jurisdiction, due to no Notice both substantively (inadequate documents) and procedurally (Nothing Served ahead of trial) 

### *Vacate the "judgment" as void for want of subject matter jurisdiction, due to no "transportation" proved: thus failure to prove standing and 

### submitting no evidence in support of the "judgment". *Vacate the "judgment" as void as a result of the trail court's having Compelled Todd's consent to "transportation" "vehicle" "motor vehicle" "drive" (in all forms) and "operate" (in all forms) and Violated Todd's right to a fair trial right to travel right (not) to contract Appellant's Brief (Todd) \SNo Notice. No Commercial ne right (not) to engage in commerce 

### /RECEIVEDN MAY 1 8 2015 TWRDCOURJOFAPPEALS, \ JEFFREYD.KYLE / 

### * Declare the entire Transportation Code either (1) 100% commercial, as is 

### the commonsense understanding, or (2) totally vague for want of definitions of "transportation" and "this state".
* Refund the impound amount for Todd's car. 

### * Award Todd costs and all other relief to which she is justly entitled. Respectfully submitted,

G^YLEEN S. TODD 2116 Juniper Trail Round Rock, Texas 78664

Appellant's Brief (Todd) 19No Notice. No Commercial nexus. 

### /"RECEIVED\ MAY 1 8 2015 Certificate of Service THIRDCOURTOF APPEALS \ JEFFREYP. KYLE / 

### By my signature below, I certify that on this the 24th day ofApril, 2015, I served a true and correct copy of this brief with it's Appendix on the following by certified mail or by 3-day or faster delivery:
Court of Appeals Third district P.O.Box 12547 Austin, Texas 78711 

# 'Ot/l^^^M

AYLEEN S. TODD

Appendix Contents Judgment and Sentence Taken After a Jury Trial Al Charge of The Court A2 Court Response to Jury Question A3 Bill of Service for Impoundment of Car A4

Appellant's Brief (Todd) 20Jeffrey D. Kyle Clerk Court ofAppeals Third District ofTexas P.O. Box 12547 Austin, Tx. 78711 court ofappeals number: trial court case number: 03-14-00386-CR 13-08168-3 May 6, 2015 Gayleen S. Todd 2116 JuniperTrail Round Rock, Tx 78664

RECEIVED MAY 1 8 2015 THIRDCOURTOFAPPEALS. " •ffFREYD. KYIP y

Certificate of Compliance

th 

### Concerning the Appellant's BriefI sent via certified mail on April 28 , and was received by the court clerk, but was not filed, here is the calculation ofwords in said document according to the computerprogram used to write it:

There are 6019 words in the document.

Gayleen S. ToddNo Notice. No Commercial nexus.THE STATE OF TEXAS VS. GAYLEEN S TODD CAUSE NO. 13-08168-3 JAIL SEN"~E^C

COUNTY COURTAT LAW#3 OF WILLIAMSON COUNTY, TEXAS JUDGMENTAND SENTENCE TAKEN AFTER A JURY TRIAL On June 02, 2014, thiscause was called fortrial. The State appeared by and throughWilliamson CountyAttorney Dee Hobbs, and ^ the above-named Defendant havingvoluntarily waived his/her rightto counsel appeared in person. • the above-named Defendant appeared in person with his/her attorney, Both parties announced "ready" for trial. Defendant was arraigned and/orwaived arraignment and the Court entered a plea ofNOT GUILTYto the offense of FAIL TO MAINTAIN FINANCIAL RESPONSIBILITY, a Class C Misdemeanor committed on or about May 15, 2013, as charged by the Information herein. Ajury of six persons was selected, empanelled, and sworn. After hearing the Information read, receiving the evidencesubmitted and the chargeoftheCourt, andhearing arguments ofcounsel, saidjury retired to deliberate and returned the following verdict in open court: "We, the Jury, find the Defendant, GAYLEEN S TODD, GUILTY of the offense ofFAIL TO MAINTAIN FINANCIAL RESPONSIBILITY as charged in the Information." Said verdict form was signed by the presidingjuror. The trial then proceeded to the punishment phasewhere Defendant elected to havehis/her punishment assessed by the samejury. Saidjurythen heard evidence regarding punishment, retired todeliberate, and returned thefollowing verdict in open court: afine of $220.00. Itistherefore ADJUDGED thatDefendantisguilty oftheoffense ofFAILTOMAINTAIN FINANCIALRESPONSIBILITY, and ishereby sentenced to pay afine of$220.00. All costs of courtincurred hereinare hereby taxed to Defendant. SPECIAL FINDINGS AND ISSUES • TheCourtAFFIRMATIVELY FINDS Defendantcommittedfamily violence inthe course ofcommitting the offensecharged. • Defendant is ORDERED to pay restitution of $ to throughtheWilliamson County Community SupervisionandCorrections DepartmentortheCountyAttorney's Office. D Defendant's driver's license is SUSPENDED for days, beginning June 3, 2014 D Ifeligible, Defendantis toreceive crediton thislicense suspensionforanyprioradministrative license revocation. • AVictim ImpactStatementwasreturnedtotheprosecuting attorneyandprovidedto theCourtforconsideration in sentencing. ORDER OF COMMITMENT The Honorable SheriffofWilliamson County is ORDERED to take Defendant into custody and keephim/her in the County Jail until expiration ofthefollowing sentence: Defendanthasbeen SENTENCEDto aterm of DAYS-injail, with creditfor days served. This sentence is to be served: • on CONSECUTIVE DAYS • on CONSECUTIVE DAYS intheWilliamson County WorkRelease Program • on CONSECUTIVE WEEKENDS • through theWilliamson County Community Service Restitution Program (Road andBridge) in lieu ofincarceration. The Defendant isORDEREDto reportto the program coordinatorat 7:45AM on the date the sentence is orderedtobegin. Said sentence shall begin Defendant has been ordered to pay the following fine and courtcosts: $ 220.00 Fine $ 222.00 Court Costs $ 442.00 TOTAL • Unless Defendant can produce a receiptshowing payment infull to the CountyClerk, do not release Defendantuntil he/she has received creditfor additional days in jail. E3 Defendant is ordered to pay said costs to the County Clerk in full by July 18, 2014 Failure to pay said costs infull by said date will result in a capias pro fine warrant being issuedfor Defendant's arrest 

### IfDefendantfails toappearforweekendjail, workrelease, orRoadandBridge, inaccordancewiththis Order, this sentenceis hereby commutedto CONSECUTIVE DAYS injail upon Defendant's arrestuntil it is satisfied. This sentence shall run CONCURRENT with the followi SIGNED June 3, 2014 

### Defendaq^^^fthumbprint• 

## iifb,.Av JUN 0 3 2014THE STATE OF TEXAS VS. GAYLEEN S TODD

DEFENDANT Mollinn arlrlrocc ' 7&7 fit£/ Mailing address Telephone number
Fax number, ifany CAUSE NO. 13-08168-3 COUNTY COURT ATLAW#3 OF WILLIAMSON COUNTY, TEXAS TRIAL COURT'S CERTIFICATION OF DEFENDANT'S RIGHT OFAPPEAL I,judge of the trial court, certify this criminalcase: El is nota plea-bargain case, and the Defendanthas therightofappeal; or
• is aplea-bargaincase, butmatters were raised bywritten motionfiled and ruled on beforetrial and notwithdrawn orwaived, and the Defendanthas the right ofappeal; or D isaplea-bargaincase, butthetrialcourthasgiven permissiontoappeal, andthe Defendanthastherightofappeal; or • is a plea-bargain case, and theDefendanthasNO rightofappeal; or • the Defendant has waived the right ofappeal.
SIGNED June 3, 2014 

### Ihavereceivedacopyofthiscertification. Ihavealsobeeninformedofmyrightsconcerninganyappe^o>tniscriminalcase,including anyrighttofile aprosepetitionfordiscretionary reviewpursuantto Rule 68 oftheTexas Rules ofAppellate Procedure. Ihavebeen admonishedthatmyattorneymustmail acopyofthecourtofappealsjudgmentand opiniontomy lastknown addressandthatIhave only 30 days in which to file apro se petition for discretionary review in the Court ofCriminal Appeals. Tex. R. App. P. 68.2 I 

### acknowledgethat, ifIwish to appeal this case and ifIam entitledto do so, itis my dutyto inform my appellateattorney, bywritten communication, ofanychangeinthe address atwhich Iam currentlyliving oranychangein my currentprisonunit. Iunderstandthat, becauseofappellatedeadlines, ifIfail totimely informmyappellateattorneyofany change in myaddress, Imaylosetheopportunity to file apro se petition fordiscretionary review.

DEFENDANT'S ATTORNEY

State Bar Number

__ Telephone number bled FaXTrarnTOT JUN 0 3 2014 

### ^ ifany

X CountyCierk,WilliamsonCq. T%NO. 13-08168-3
The State ofTexas § in the county courtat law § VS. § NUMBER THREE § GAYLEEN S. TODD § WILLIAMSON COUNTY, TEXAS

CHARGE OF THE COURT
Ladies and Gentlemen ofthe Jury: The Defendant, GAYLEEN S. TODD, stands accused by information with the offense ofFailure toMaintain Financial Responsibility, itbeing alleged that saidoffense wascommitted in the territorial limits of the City of Round Rock, Williamson County, Texas, on or about the 

### 15th day ofMay 2013, to which charge the Court has entered a plea of4iNot Guilty" for the defendant. I now give the following instructions in this case:
I. Ourstatutes provide that a person may not operate a motor vehicle in this State unless financial responsibility is established for that vehicle. Statutes provide further that as acondition ofoperating amotor vehicle inthis state, the 

### operator of said vehicle on request shall provide to a peace officer evidence of financial responsibility by exhibiting: (1) a motor vehicle liability insurance policy; (2) a filed surety bond; (3) adeposit ofcase orsecurities with comptroller; (4) adeposit ofcash orcashier's check with countyjudge; or (5) acertificate ofself-insurance issued incompliance with statute. It is a defense to prosecution that the person charged produces to the court proof of 

### financial responsibility thatwasvalid atthe time thatthe offense occurred. It isalso adefense to 

### prosecution that the person operating avehicle inviolation ofthis section was in possession for the solepurpose ofmaintenance orrepair and was notowned inwhole or in part by thatperson. Our statutes further provide that thissection does not apply to the operation of a motor vehicle that is a former military vehicle or is at least 25 years old; is used for exhibitions, club activities, parades, and otherfunctions of publicinterest and not for regulartransportation; and for which the owner files with the department an affidavit, signed by the owner, stating that the vehicle is a collector's item and used only forexhibitions, club activities, parades, and other functions of public interest and not forregular transportation. The law does not apply to the operation of aneighborhood electric vehicle or golfcart that isoperated only asauthorized by statute; or avolunteerfiredepartment for theoperation of a motorvehicle the title ofwhich is

Jl;I<Y GlAKl.l l>uli ' f,i f»held in the name of a volunteer fire department unless a person is operating that vehicle in a manner inconsistent with a volunteer fire department.

II. In your deliberations, you shall use the following definitions: "Motor Vehicle " means a self-propelled vehicle designed foruse on a highway, a trailer or semitrailer designed for use with a self-propelled vehicle, or a vehicle propelled by electric powerfrom overhead wires and no operated onrails. Theterm does notinclude: (A) a traction engine; (B) a road roller or grader; (C) a tractor crane; (D) a power shovel; (E) a well driller; (F) an implement of husbandry; or (G) an electricpersonal assistive mobility device as defined by statute
III. Now therefore, if you believe from the evidence beyond a reasonable doubt that on or about the 15th day of May2013, thedefendant, GAYLEEN S. TODD, did then andthere, in the territorial and corporate limits of the City of Round Rock, in Williamson County, Texas, 

### operate a motor vehicle on a public street, towit: Gattis School Road, when there was not in effect any authorized method ofestablishingevidence offinancial responsibility for that vehicle, contrary to theordinance ofthe city ofRound Rock, and the defendant was not inpossession of the vehicle for the solepurpose ofmaintenance orrepair and has notproduced proof offinancial 

### responsibility that was valid at the time of the offense, was not operating a former military vehicle or is at least 25 years old, was notused forexhibitions, clubactivities, parades, and other 

### functions ofpublic interest and not for regulartransportation, the vehicle was not aneighborhood electric vehicle, golf cart or a volunteer fire department vehicle beingoperated in compliance 

### with being avolunteer fire department vehicle, you will find the defendant ,;Guilty." Ifyou do not sobelieve or ifyou have areasonable doubt thereof, you will acquit thedefendant and say by your verdict "Not Guilty."

IV. The law of the State of Texas provides that intent is not an element which must be proven by the State for theoffense ofFailure toMaintain Financial Responsibility.
The prosecution must prove each and every element of the offense beyond a reasonable

JllO GlAKl.i ''vdoubt. VI. 

### Allpersons are presumed to be innocent. The law does not require adefendant to prove his/her innocence orproduce any evidence at all. The presumption of innocence alone is 

### sufficient to acquit the defendant, unless thejurors are satisfiedbeyondareasonable doubt ofthe defendant's guiltaftercareful and impartial consideration ofall the evidence inthe case.

VII. Under our Constitution and laws, every defendant has the right to remain silent and not to 

### testify. Ifthe Defendantdid not testify at trial, you are nottodiscuss orconsiderthatfact in your deliberations. VIII. 

### You cannot inferguiltfrom thefact thataperson hasbeen arrested, confined, indicted, or 

### otherwise chargedwithan offense. Youarefurther instructedthatthe Complaintand Information 

### against the Defendant are not evidence inthe case. Thesole use ofthe Information isto charge the offense and to inform the Defendantofthe alleged offense. The reading ofthe Information to 

### the jury cannot be considered as a fact or circumstance against the Defendant in your deliberations. IX. You are charged that you are permitted to receive evidence regarding the case orany 

### witness therein only from the witness stand and the exhibits that have been admitted into 

### evidence bythejudge. Nojuror ispermittedtocommunicate toany otherjurorabout anything he or she may have heard concerning the casefrom any source other than the witness stand and the exhibits.


### In deliberating the case, you are not to refer to ordiscuss any matter or issue not in evidence before you. However, you are permitted to make reasonable inferences from the evidence. XI. You are the exclusive judges of thefacts proved, of the credibility ofthe witnesses and other sources ofevidence, and ofthe weight to be given to the testimony andevidence, but you are bound to receive the law from the Court, which is herein given you, and be governed thereby. Do not letprejudice or sympathy play apart in yourdeliberations.

JlIO GlAKln '' MXII. 

### After argument of counsel, you will retire and select one of your members as your 

### PresidingJuror. It isthe duty ofyourPresidingJuror to preside at yourdeliberations and to vote with you inarriving at averdict. Your verdict must beunanimous. Afteryou have arrived at a unanimous verdict, your Presiding Juror must sign the attached form that conforms to your verdict. In no eventshall thePresidingJuror sign more than oneofsuchforms.

XIII. 

### During your deliberations, you shall not separate from each other, nor talk with anyone not ofyourjury. No one has any authority to communicate with you except the Officerwho has 

### you in charge. You may communicate with this Court in writing, by a note signed by your 

### PresidingJuror, through the Officerwho has you in charge. Do notattemptto talk to the Officer. SignedandSubmittedtotheJury on this, the -"' day of ,,,. vV ,2014.

" -\ JUDGE PRESIDING

J.;i<> Thau..i l>A(:i 4 0i (}THE STATE OF TEXAS
VS.
GAYLEEN S. TODD NO. 13-08168-3

IN THE COUNTY COURT AT LAW
NUMBER THREE
WILLIAMSON COUNTY, TEXAS

VERDICT OF THE JURY 

### We, the Jury, find the Defendant, GAYLEEN S. TODD, GUILTYofthe offense of Failure to Maintain Financial Responsibility.
Signedonthis, the dayof , 2014.

PRESIDING JUROR

JUU\ GlAKtil I' \M •> <>! i'iNO. 13-08168-3

THE STATE OF TEXAS IN THE COUNTY COURTATLAW
VS. NUMBER THREE
GAYLEEN S. TODD WILLIAMSON COUNTY, TEXAS

VERDICT OF THE JURY 

### We, the Jury, find the Defendant, GAYLEEN S. TODD, NOTGUILTYofthe offense ofFailure to Maintain Financial Responsibility.
Signedonthis, the dayof , 2014.

PRESIDING JUROR

Jl'KV GlAKtilThe State ofTexas

vs. GAYLEEN S. TODD NO. 13-08168-3

IN THE COUNTY COURTATLAW
NUMBER THREE WILLIAMSON COUNTY, TEXAS
COURTRESPONSE TO JURY QUESTION The Courtunderthe law is notpermitted toanswerthequestion you presented. Please consider 

### onlythe instructions that havebeengiven to you and continuewith yourdeliberations.
SignedandSubmitted totheJury onthis, the 

### $Cck dayof \) W-w? , 2014.

JUN 0 3 2014 1r®&- 'rl w'"iamsonCo.,TYBill ofService TDLR# 0644778VSF Date: OS-/S-/S Sunrise Towing 1101 N. Industrial Blvd #A Round Rock, TX 78681 (512)238-8229 Owner's or Lienholder's Name : ZJohm Kachntai' Address: £/S3 (TsjaJtZyfo^t P<0. 

### City,State, Zip: Sx/n (Marc**; TY78C66 To whom it may concern: (perVehicle Storage FacilityAct, Occupation Code,Title 14, Ch. 2303) Your vehicle has been impounded and stored at Sunrise Towing, 1101 N. Industrial Blvd. #A R.R., TX78681, Tel: (512) 238-8229, #0644778VSF. The vehicle was impounded by the authority of: K-&. P. O andaccepted for storageon os-/S-i^ . Thevehicle wastowed from IES<S Ga£L\ ^U<~S**/. (? ?(/*• at UWW on QS-tS-13 bySunrise Recovery, 3iO*> K.lH3S Ste. ADO , R.R., TX 78664,Tel: (512) 238-8229.Tow Company # 006452258C. The vehicle isa QOOO (Year) ffkndta (Make)fhZco (Model) UJhifS (Colort. bearingCg3/Wf2(License Plate Number) TY andJTill/gJ^MVflafV?^ (V1N). Vehicles released between 8:00A.M -12:00A.M Monday

- Saturday and 8:00A.M - 5:00 P.MSunday. National Holidays Closed. Vehicles released after hours within 1(one) hours notice. The following charges have accrued. "Total storage charges cannot be computed until vehicle is claimed. The storage charge will accrue daily untilvehicle is released." Daily Storage rate: $ 20 per day S ~ Notification Fee I Impoundment Fee S5Q.te Sales Tax (8.25 %) Sub-total Tow Rate Winching Dollies Clean Up Transfer to Body Shop Extra Time (stand by) Additional Labor Other: Total C 

### Removedby VY 'JA^^f/^^ , wrfOperator IJ$J/ Date: OS-IS-1J

herebyacceptthVabovedescribedvehicle andverify thatIhave therighttopossess the vehicle, In addition. Ihave reviewed details ofcharges on the original tow ticket or tow invoice and Ihave been advised ofthe Precinct and the Justice ofthe Peace having jurisdiction in which the vehicle was towed. Questions or unresolved complaints about stored vehicles may be directed to: Texas Department of Licensing & Regulation, P.O. Box 12157. Austin. Texas 78711 or 1-800-803-9202. wwv/.license.state.tx.us/Complaints/DRIVER NAME: WRECKER LIC.# M.BoJlos 1420?

Phone # (512)238-8229 TOW TRUCK LICJ INVOICE # 

## Sunrise Recovery 3103 M. 1H3S. Suite#'^oo Round Rock, TX 78664 TDLR#006452258C TDLR#0644778VSF Date 0S-/S-/3 

### TIME/1:42 @ PM LOCATIONOFVEHICLE /3>SS GaJtfil Sebcvf /&. /?. rZ 7* PQ 7^///c S/0/7 COLOR fc^/fr YEAR QOOO MA^ /?7«?<2fcf 

### LIC. PLATE# 0S3MGJ STATE MODELProfej^ £<$ vehicleldno. crm/ej-^ MYoao Z33C* DESTINATION OFVEHICLE 3tO$ H Iff 3^ 5u/fc
. 4-OQ 

# Ht XiTOWEDPERORDEROF: STATEPOLICE "^LOCALPOLICE PROPERTYMANAGEMENT Vehicle Storage Begining Date: as-/s"ts Ending Date: VEHICLE STORAGE FACILITY 1101 N. INDUSTRIAL BLVD. #A ROUND ROCK, TX 78681 TDLR#0644778VSF or-(Stz

Inventory ofvaluableproperty visible insidevehicle'spassengercompartment Front SeatArea/Glove Box: Rear Seat Area: Trunk/Bed Other: Damage to Vehicle/Missing Parts: DOORS

ODOMETER READINGS: STARTING POINT: PICKUP: DROP OFF: CHARGES Once this vehicle leaves 

### the property,Sunrise

Towing & Sunrise Recovery, will notbe

responsible for any 

### damages or claims. DIRECT ALL COMPLAINTS TO TEXAS DEPT. OF LICENSING & REGULATION P.O.BOX 12157 AUSTIN, TX 78711

(512)463-6599 EMAIL: TOWTNG@LICENSESTATE.TX.US WWW.LICENSESTATE.TX.US/COMPLAINTS/ AUTHORIZATION TO REMOVE VEHICLE: IgiveSunriseTowingmypermissionandauthorizationtoremovethis vehiclerthxj whereitisparkedontheproperty. Signaturi Print Narrii IMPOUND TOW FEE DOLLIES: WINCHING: CLEAN UP: TRANSFER TO BODYSHOP EXTRA TIME: ADDITIONAL LABOR: OTHER: *?s.

TOTAL CHARGE: 

### 12£ a> ca.--7D1N34^0DDDEDfl575h30UNtTEDST&TESPOSTALSERVICE.U.S.POSTAGEPAIDROUNDROCK.TX78664APR24,15AMOUNT$8.6600113871-02100078711~~"§u~iro-W5inc^*^v*,7^7//