NO. 06-15-00049-CR

IN THE COURT OF APPEALS, 6th DISTRICT

TEXARKANA, TEXAS

---------------------------------------------

KELLY RAY TADLOCK, 

Appellant,

VS.

THE STATE OF TEXAS,

Appellee,

---------------------------------------------

Appealed from No. 1424225

the 8th District Court Hopkins County, Texas

---------------------------------------------

BRIEF OF DEFENDANT

---------------------------------------------

FOR THE DEFENDANT

FRANK R. HUGHES

Attorney at Law

P. O. Box 8145

Greenville, Texas 75404

State Bar No.: 10236500

ORAL ARGUMENT IS NOT REQUESTED

ACCEPTED

06-15-00049-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

7/10/2015 9:48:29 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 7/13/2015 8:08:00 AM DEBBIE AUTREY Clerk
2

NAMES OF ALL PARTIES

Appellant certifies, pursuant to T.R.C.P.38.1(a), that the following is a 

complete list of the names of all the parties and all persons otherwise interested in 

the outcome of this case:

APPELLANT: KELLY RAY TADLOCK

APPELLANT'S COUNSEL: FRANK R. HUGHES of Greenville, Texas; 

FRANK R. HUGHES

P. O. BOX 8145

Greenville, TEXAS 75404

903.456.2703

APPELLEE: THE STATE OF TEXAS

APPELLEE'S COUNSEL: 

Will Ramsay

110 Main St.

Sulphur Springs, TX 75482

Phone: (903) 885-0641
3

SUBJECT INDEX

Page

NAMES OF ALL PARTIES .................................. 2

REQUEST FOR ORAL ARGUMENT ............................. Title

SUBJECT INDEX .............................................. 3, 4

INDEX OF AUTHORITIES ................................... 5,6

STATEMENT OF THE CASE ................................. 7,8

ISSUES PRESENTED/ POINTS OF ERROR NOS. 1-2............. 9

STATEMENT OF FACTS..................................... 10

SUMMARY OF ARGUMENT.................................... 11 

ARGUMENT AND AUTHORITIES IN SUPPORT OF

POINT OF ERROR NO. 1 ............................. 11-16

ARGUMENT AND AUTHORITIES IN SUPPORT OF

POINT OF ERROR NO. 2............................. 17-25

PRAYER ................................................ 26
4

CERTIFICATE OF SERVICE ................................ 26, 27

CERTIFICATE OF WORD COUNT 27
5

INDEX OF AUTHORITIES 

CASES CITED:

Brooks v. State, 323 S.W.3d 893, 912 (Tex. Crim. App. 2010) 

(citing Jackson v. Virginia, 443 U.S. 307, 319 (1979)); 11

Casey v. State, 924 S.W.2d 946, 949 (Tex.Crim.App.1996) 18, 24

Collier v. State, 959 S.W.2d 621, 625 (Tex.Crim.App.1997) 18 

Hartsfield v. State, 305 S.W.3d 859, 863 (Tex. App.-Texarkana 2010, 

pet. ref'd) 11 

(citing Clayton v. State, 235 S.W.3d 772, 778 (Tex. Crim. App. 2007))

Hooper v. State, 214 S.W.3d 9, 13 (Tex. Crim. App. 2007) 12

(citing Jackson, 443 U.S. at 318–19)

Malik v. State, 953 S.W.2d 234, 240 (Tex. Crim. App. 1997) 12

Moore v. State, 999 S.W.2d 385, 395 (Tex.Crim.App.1999), 

cert. denied, 530 U.S. 1216, 120 S.Ct. 2220, 147 L.Ed.2d 252 (2000) 19

Reeves v. State, 06-00-00103; 46 S.W.3d 397 (Tex.App.—Texarkana 2001) 17

White v. State, 06-13-00110-CR 11
6

STATUTES

TEX. CODE CRIM. PROC. ANN. art. 46.02, § 1A(a) (Vernon Supp. 2001) 17

TEX. CODE CRIM. PROC. ANN. art. 46.02, §1A(b) (Vernon Supp. 2001) 17

TEX. CODE CRIM. PROC.ANN. art. 42.07(2) (Vernon Supp. 2001); 18

TEX. CODE CRIM. PROC. ANN. art. 46.02, § 2(b) (Vernon 1979) 18
7

NO. 06-15-00049-CR

IN THE COURT OF APPEALS, 6th DISTRICT

TEXARKANA, TEXAS

---------------------------------------------

KELLY RAY TADLOCK, 

Appellant,

VS.

THE STATE OF TEXAS,

Appellee,

---------------------------------------------

Appealed from No. 1424225

the 8th District Court Hopkins County, Texas

---------------------------------------------

BRIEF OF DEFENDANT

-----------------------------------------

TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS:

COMES NOW, KELLY RAY TADLOCK, Defendant, through his attorney 

and files this Brief in his Appeal. Pursuant to the Texas Rules of Appellate 

Procedure, references to the record, which consists of the Court's Record, in 1 
8

volume and the Reporter's Record, in 10 Volumes. They will be noted in 

parentheses as (Cr_) if in the Court's Record: (Rr_) in the Reporter's Record; 

STATEMENT OF THE CASE

On 08/01/2014, the Defendant, Kelly Ray Tadlock was arrested, charged and 

indicted twice for INDECENCY W/CHILD SEXUAL CONTACT, each alleging 

separate individual sisters, referred to as CW A and CW S, in Sulphur Springs, 

Hopkins County, Texas.(Cr10) On 17 December 2014 the Defendant entered a 

plea of guilty, after admonitions, and a PSI was ordered. (RrV4) A problem 

developed when the Defendant apparently told the PSI officer that he was not 

guilty of the charged offense (RrV5p6) that he was ―scared of a jury, and felt 

pressured by his trial attorney, and didn’t know how he could prove his 

innocence.‖ The Judge instructed the PSI officer to cease the interview. On 31 

December 2014 after questioning by the Judge, the court refused to accept a plea of 

guilty. 
9

Jury was waived, and trial to the Court began on February 3, 2015 (RrV7p7) the 

Defendant was found guilty on one charge, involving CW A but not guilty on the 

second CW S, a second PSI was ordered, the Defendant was then sentenced to 

twenty years. Appellant was taken into custody. Notice of Appeal was filed on 

March 3, 2015(Ctr133). The Court's Record was timely filed; a Request for 

Extension of Time to file Brief, was filed; and granted making the brief due 6 July

2015; this brief is being filed on 10 July 2015, along with a Motion for Late 

Filing, from the Court's errors in the conduct of the trial the defendant appeals. 
10

ISSUES PRESENTED-POINTS OF ERROR 

ISSUE 1: THE VERDICT IS AGAINST THE GREAT WEIGHT OF THE 

EVIDENCE 

ISSUE 2: THE TRIAL COURT ABUSED ITS DISCRETION WHEN IT 

FAILED TO ORDER SUA SPONTE A PSYCHIATRIC EXAMINATION OF THE 

DEFENDANT TO DETERMINE IF THE ASSORTMENT OF DRUGS THE 

DEFENDANT WAS TAKING AFFECTED HIS ABILITY TO HAVE 

SUFFICIENT MENS REA IN A SEXUAL CONTACT CASE and WHETHER HE 

WAS COMPETENT TO PROCEED FOLLOWING THE REJECTION OF THE 

INITIAL PLEA OF GUILTY AND CANCELLATION OF THE PRE-SENTENCE 

INVESTIGATION REPORT 
11

STATEMENT OF FACTS

The Defendant is a step uncle to the CWS and her sister CWA (RrV7p43). 

On July 15, 2014 the girl’s mother left them with him, to babysit while she went to 

work; when she returned she was told by both CWS and younger sister CWA that 

the defendant had been talking about sex to both sisters; and had touched them 

both through their clothes, the day before (RrV7p53,52p22-16). Mom called the 

Defendant who denied touching even talking about sex to them; (RrV7p). Mom 

took the girls to her mother’s house where they repeated their allegations to Cathy 

Tadlock, the Grand mother, and Carter Tadlock, stepfather of Mom and Father of 

Defendant (RrV7p57L22-25),. The family was uncertain as to what to do next, S, 

the youngest Complaining Witness told them to call the police (RrV), which they 

did, she also testified she got to watch TV at her Grand Mother’s.-TV shows her 

Mom wouldn’t permit. Officer Jason Reneau was the responding officer, took a 

cursory statement and left a form for Mom to complete, telling her that she would 

be contacted (RrV7). She was contacted and arrangements were made to have the 
12

girls interviewed at the closest CAC, in Texarkana, following the meeting with a 

fully qualified professional- the decision was made to file the instant charges and 

arrest the Defendant. He was taken into custody where he remained until he was 

released on a PR bond following a plea that was later abandoned. 

SUMMARY OF THE ARGUMENT

Defendant's complaints are of the Sufficiency of the Evidence and the Trial 

Court relying on his own training to make a decision concerning the Defendant’s 

mental acuity, rather than order a psychiatric examination. 

POINT OF ERROR NO. 1- THE VERDICT IS AGAINST THE GREAT 

WEIGHT OF THE EVIDENCE 

ARGUMENT AND AUTHORITIES

As this court said recently in White v. State, 06-13-00110-CR 

―In reviewing the legal sufficiency of the evidence, we consider all the evidence in 

the light most favorable to the trier of fact's verdict to determine whether any 

rational jury could have found the essential elements of the offense beyond a 
13

reasonable doubt. Brooks v. State, 323 S.W.3d 893, 912 (Tex. Crim. App. 2010) 

(citing Jackson v. Virginia, 443 U.S. 307, 319 (1979)); Hartsfield v. State, 305 

S.W.3d 859, 863 (Tex. App.-Texarkana 2010, pet. ref'd) (citing Clayton v. State, 

235 S.W.3d 772, 778 (Tex. Crim. App. 2007)). We examine legal sufficiency in 

light of the Brooks opinion, while giving deference to the responsibility of the trier 

of fact "to fairly resolve conflicts in testimony, to weigh the evidence, and to draw 

reasonable inferences from basic facts to ultimate facts." Hooper v. State, 214 

S.W.3d 9, 13 (Tex. Crim. App. 2007) (citing Jackson, 443 U.S. at 318–19). 

APPLYING THE LAW TO THE FACTS: 

Defendant had been a very good trusted friend of the family during the 

forced absence of the Step Father James York, (RrV7L12,13). The mother of both 

complaining witnesses. Kristina York, Mom, had known him since she was 16, 

and considered him like a brother, which he was, a step brother with a close 

relationship. (RrV7p68L12-20); he had been at the house for two nights before the 

first telling of the A story, Mom and girls drove him home on the day following the 
14

incident (RrV7p77L18-24) and it was only after this short trip that A told her story 

for the first time. He was a frequent visitor to the family home of the girls and 

their Mom, Kristina York (RrV7p71L1-17). To the extent that he had his laundry 

washed there. (RrV7p48L1-10). Mom had left the girls with him on other 

occasions with no apparent improper activity. (RrV7p73L23-24). 

On 15 July 2014, Mom came home, took Defendant to his home, and upon 

returning to her home CWS and CWA told her that Uncle Kelly had begun talking 

about sex with them. (RrV7p50L21-23). CW A told her Mom that Uncle Kelly 

was talking about it, and also about Mom and her husband and Uncle Kelly and his 

girlfriend, her Aunt Kay. And that he touched her vagina and made her touch his 

penis, even pulling her hand over to him and forcing a touching. And that it had 

occurred on 14 July 2014. 

CW S, followed her sister’s lead and added that it had happened a month 

before, too. (RrV7p51,52). S and A began to argue over what and when it had 

happened and when while outcry Mom was talking to them about it. When asked 
15

on cross examination Mom explained that the girls said Defendant talked about 

her, her husband James York and also about Defendant and his former partner, 

Aunt Kay . (RrV7p80L1-7); Mom’s testimony, 

·4·· · · · Q.· ·And was that about marriage, or was 

that

·5··about sex?

·6·· · · · A.· ·They didn't say.··That's all I got out 

of

·7··them.··I didn't ask them any further.

Mom then called the Defendant and asked about what had happened, he said 

instantly, that he did not do anything (RrV7p58L15, 16). Mom called her mother 

about it and arranged to take the girls over to the house her mother shared with the 

father of the Defendant. (RrV7p57). She, accompanied by the girls, drove over to 

Defendant’s apartment shortly after the conversation. They delivered a blanket 

Defendant had left at her home, along with retrieving some dishes he had taken to 

his place after a July 4th celebration. This happened AFTER the outcry to Mom. 

(RrV7p59L1-4). 

Defendant told Mom that he had talked about marriage with the CW S. 
16

There was no discussion of touching, and Mom indicated she wasn’t sure what she 

was going to do about calling the police. . (RrV7p59L21-25, p60L1-12). Mom 

then took girls and went to her Mother’s house where the story was retold to Carter 

and Cathy Tadlock, father of defendant, step grandfather of the CWA and his wife, 

mother of CW’s Mom. Following the tell, there was conversation of what to do 

next and CW A said call the police. .(RrV7p60L16-24). 

The Defendant denied that he had ever touched either of the complainants 

inappropriately (RrV8p43L7-8). Under cross examination he explained the 

presence of a morning erection, and its being noticed by CW A (RrV8p48, 49) that 

he took her off his lap, and told her that he should not discuss boy, girl parts and 

sex with them, that was better discussed by their Mom. And that he and CW S had 

talked with him about marriage. His testimony was consistent with his explanation 

to his brother. (RrV7p114L11-19 ). 

SUMMARY POINT OF ERROR 1 

The girls were arguing over what happened during the original outcry given to 
17

themother; when asked about what else was discussed, Mom was unsure saying 

that the conversation may have been about sex or marriage, she doesn’t know, 

because that was all she could get out of them. The family was unsure how to 

proceed is proven by their actions. They apparently waited for several hours 

before even contacting the police. The girls had much time to get their stories 

straight between the initial tell to their Mom, during which they argued, then to the 

natural Grandmother and Step-Grandfather. And finally to the CAC interviewer. 

CW S couldn’t remember at trial, resulting in a finding of not guilty by the court, 

however; CW A, was again calm and had no trouble in reciting her story as if 

coached or well rehearsed. A simple story told by a young girl. One need only 

read or watch ―The Crucible‖ to understand. NO complaints by anyone before. 

He had been offered and agreed to a very good, fair ―deal‖; so beneficial to him 

that it remained to be seen if Judge would have even approved it: 

But, at the time it was very fair; his lawyer agreed he should take it. Yet he 

didn’t. 
18

ISSUE 2 THE TRIAL COURT ABUSED ITS DISCRETION WHEN IT 

FAILED TO ORDER SUA SPONTE A PSYCHIATRIC EXAMINATION OF THE 

DEFENDANT TO DETERMINE IF THE ASSORTMENT OF DRUGS HE WAS 

TAKING ON A CONSTANT BASIS AFFECTED HIS ABILITY TO HAVE 

SUFFICIENT MENS REA IN A SEXUAL CONTACT CASE and WHETHER HE 

WAS COMPETENT TO PROCEED FOLLOWING THE REJECTION OF THE 

CONTINUATION OF THE PRE-SENTENCE INVESTIGATION REPORT 

As this court said in, Reeves v. State, 06-00-00103; 46 S.W.3d 397 

(Tex.App.—Texarkana 2001) 

“A person is incompetent to stand trial if she does not have (1) 

sufficient present ability to consult with her lawyer with a reasonable degree 

of rational understanding; or (2) a rational as well as factual understanding 

of the proceedings against her. TEX. CODE CRIM. PROC. ANN. art. 46.02, 

§ 1A(a) (Vernon Supp. 2001). A defendant is presumed to be legally 

competent unless proved incompetent by a preponderance of the evidence. 

TEX. CODE CRIM. PROC. ANN. art. 46.02, §1A(b) (Vernon Supp. 2001).
19

Further, a defendant must be competent at the time of her 

sentencing. TEX. CODE CRIM. PROC.ANN. art. 42.07(2) (Vernon Supp. 

2001); Casey v. State, 924 S.W.2d 946, 949 (Tex.Crim.App.1996). During 

any part of the proceeding, evidence of a defendant's incompetency may 

be brought to the trial court's attention from any source. TEX. CODE CRIM. 

PROC. ANN. art. 46.02, § 2(b) (Vernon 1979). When evidence of 

incompetency during the proceeding is produced, the court must conduct 

an inquiry, referred to as a "Section 2(b) inquiry" (outside the presence of a 

jury) to determine whether there is evidence to support a finding of 

incompetency to stand trial. Id. Such an inquiry is required only if the 

evidence brought to the trial court's attention is such as to raise a "bona 

fide" doubt in the trial court's mind as to the defendant's competency. 

Collier v. State, 959 S.W.2d 621, 625 (Tex.Crim.App.1997). In general, a

"bona fide" doubt is raised only if the evidence indicates recent severe 

mental illness, at least moderate mental retardation, or truly bizarre acts by 
20

the defendant. Id. Prior hospitalization and treatment for depression do not 

per se warrant the trial court's holding of a competency hearing. Moore v. 

State, 999 S.W.2d 385, 395 (Tex.Crim.App.1999), cert. denied, 530 U.S. 

1216, 120 S.Ct. 2220, 147 L.Ed.2d 252 (2000). When the trial court holds a 

Section 2(b) hearing and any evidence (i.e., a quantity more than none or a 

scintilla) is presented that could rationally lead to a determination of 

incompetency, and regardless of evidence showing competency, the trial 

court must impanel a separate jury to determine the defendant's

competency to stand trial. TEX. CODE CRIM. PROC. ANN. art. 46.02, § 

4(a) (Vernon Supp. 2001); Moore, 999 S.W.2d at 393.” 

APPLYING FACTS TO THE LAW: 

As the trial court stated, from his vantage point on the bench, the Defendant 

had consulted with his attorney at the time of entering his initial plea of guilty. 
21

And the Defendant pled guilty after considerable admonitions, from the court. 

(RrV4p). 

Then as the Defendant, purportedly stated, that he was not really guilty that 

he didn’t want to go to prison, felt pressured by his attorney, and didn’t see how he 

could prove his innocence: these statements were made at the pre-sentence 

interview the very next morning after the plea. (RrV4p5) Absolutely begs the 

question, how could he see how he could prove it with the mood of law 

enforcement and the public today? 

On 31 December 2014, the court had been informed that the Defendant 

again was intending to enter a plea of guilty (RrV4p) . When questioned by the 

Judge about his prior change of heart, he responded that he was conflicted, and the 

court said

·6·· But I simply can't accept a plea of

guilty from somebody who maintains that they're only

·7··doing it to avoid the possibility of adverse

·8··consequences.

·9·· · · · · · · · · THE DEFENDANT:··I'm not just --

I'm
22

10··not guilty -- I -- I believe that if the girls say

11··that I violated them in some way, then I must have.

12·· · · · · · · · · THE COURT:··Okay.··And I want you 

to

13··know I appreciate that.··I don't know what's going 

on

14··in your mind.··That is insufficient for me to 

support

15··a plea of guilty.··Okay?··That's insufficient.··And

16··so what I'm going to do is set the matter for 

trial,

17··and we'll be set for trial on February 5 -- no --

18··Monday, February 2. (RrV4p16) 

At the time of this exchange the court was aware of the Defendant’s legal 

drug usage, the questioning about illegal drugs at the CWA family home was 

denied; and again made the decision that he announced at the time of the original 

plea, he was a mental health care professional, and

· · · · · · · THE COURT:··Okay.··Do you need a

24··chair?

25·· · · · · · · · · THE DEFENDANT:··(Nods.)

Page 13

·1·· · · · · · · · · THE COURT:··Would you please get 

him a

·2··chair.

·3·· · · · · · · · · (Defendant seated in chair at 

bench.)

·4·· · · · · · · · · MR. LOYD:··Judge, you understand 

that

·5··one of the -- and I'm not intending to interrupt, 

but
23

·6··one of the medications that he is on is obviously 

for

·7··anxiety.

·8·· · · · · · · · · THE COURT:··Which medication?

·9·· · · · · · · · · MR. LOYD:··And it appears to me

10··that --

11·· · · · · · · · · THE DEFENDANT:··I'm overwhelmingly

12··anxiety right now.

13·· · · · · · · · · THE COURT:··Say it again?

14·· · · · · · · · · THE DEFENDANT:··My anxiety level 

is

15··through the roof right now, Your Honor.

16·· · · · · · · · · THE COURT:··Okay.

17·· · · · · · · · · THE DEFENDANT:··In my heart of

18··hearts --

19·· · · · · · · · · MR. LOYD:··Wait.

20·· · · · · · · · · THE DEFENDANT:··-- I believe that.

THE COURT:··Well, Mr. Tadlock,

22··here's -- you've told me -- and I've -- I began to

23··see you shake and tremble.··I got concerned about

24··your safety standing, which is why I got you a 

chair.

25··And I've been told that you're on -- what do you 

take

Page 14

·1··for anxiety?

·2·· · · · · · · · · THE DEFENDANT:··I'm on hydroxyzine

·3··right now three times a day.

·4·· · · · · · · · · THE COURT:··Is that a generic form 

of

·5··what?··I'm not familiar with that.

·6·· · · · · · · · · THE DEFENDANT:··I'm not sure what 

the
24

·7··generic form is.

·8·· · · · · · · · · THE COURT:··But it's an 

antianxiety

·9··medication, much like Clonazepam?

10·· · · · · · · · · THE DEFENDANT:··Yeah, something 

like

11··that.

12·· · · · · · · · · THE COURT:··Okay.··And you take 

that

13··on a regular basis, not as needed?

14·· · · · · · · · · THE DEFENDANT:··Three times a day.

15·· · · · · · · · · THE COURT:··Okay.

16·· · · · · · · · · THE DEFENDANT:··Cymbalta three 

times a

17··day for acute chronic depression.

18·· · · · · · · · · THE COURT:··Right.

19·· · · · · · · · · THE DEFENDANT:··High blood 

pressure

20··pill, cholesterol pill; gabapentin, which is a

21··generic; Neurontin for my nervous system; Ambien to

22··help me sleep.

23·· · · · · · · · · THE COURT:··Right.

24·· · · · · · · · · THE DEFENDANT:··Amitriptyline as 

an

25··antianxiety and sleep aid; Symbicort for my 

breathing

Page 15

·1··because I've had asthma, emphysema, COPD, and 

chronic

·2··bronchitis.

·3·· · · · · · · · · THE COURT:··Okay.··Well, again --

and

·4··I'll make the same statement, having worked in the
25

·5··field for a long time, I don't see anything about

·6··your mental status that would render you what the 

law

·7··would call incompetent to stand trial.··There's not

·8··even the mere suggestion.··It's never been 

suggested

·9··to me, and it's clear that a person can be on a 

great

10··deal of medication and still participate in their

11··defense, which we need.

This Court in Reeves, infra, said, “We review a trial court's decision 

that the evidence at a Section 2(b) hearing did not raise the issue for 

submission to a jury by viewing the evidence in the light most favorable to 

the party with the burden of securing the finding, disregarding contrary 

evidence and inferences. Casey, 924 S.W.2d at 948 n. 4. Viewing the 

above evidence in the light most favorable to Reeves' position, we

conclude that the trial court did not err in failing to conduct a competency 

hearing. There was no testimony regarding Reeves' present ability to 

consult with her lawyer with a reasonable degree of rational understanding 
26

or whether she had a rational as well as factual understanding of the 

proceedings against her. There was evidence regarding her drug addiction 

and a suicide attempt, but this evidence did not reflect on her ability to 

understand or participate in the proceedings on that day.”

In the instant case, the Defendant obviously did not understand or participate 

in the decision making process with his attorney. This was the second attempt by 

the Defendant to enter a plea of guilty, after discussing his options with his 

attorney. The Court should have Sua Sponte ordered a mental examination of the 

Defendant to determine how great the influence of the plethora of medications he 

was taking was having on the Defendant’s ability to understand and participate in 

the proceeding. Or fully understand or remember what did happen? He says if the 

girls say I did, I must have? 

PRAYER

Wherefore, Defendant prays this court reverse the judgment of the trial court 
27

and order the case dismissed or grant a new trial, and for such other relief to which 

he may be entitled. 

Respectfully submitted,

 ___/s/_Frank R. Hughes_

FRANK R. HUGHES

Attorney at Law

P. O. Box 8145

Greenville, Texas 75404

(903)456-2703

State Bar No.: 10236500

ATTORNEY FOR DEFENDANT

CERTIFICATE OF SERVICE

I hereby certify that on July 8, 2015, a true and correct copy of the foregoing 

document was mailed all counsel of record, set out below. 

/s/Frank R. Hughes 

FRANK R. HUGHES 

Will Ramsay, 

District Attorney 8th Judicial District 

110 Main St.

Sulphur Springs, TX 75482 
28

wramsay@hopkinscountytx.org

Certificate of number of words 

There are 3922 words in this document

/s/Frank R Hughes

Frank R. Hughes