PD-1403-15 CAUSE NO. 38660
APPEAL NO. 03-14-00173-CR
BRIAN TAYLOR ' - ' '" ' IN THE COURT OF THE RECEIVED IN CRIMINAL APPEALS of tex£§! NONCRIMINAL APPEALS STATE OF TEXAS NOV 20 2015 FILED IN MOTION FOR A FREE REPORTrE-R^R^a^QN, M^frAfr Abel ACQSta, C!@ri< • MOV 2 0 2315 TO THE CLERK OF SAID COURT:
NOW COMES BRIAN TAYLOR, APPELLANT, ApgbAg^aN^'^ESEECTFULLY MOVES THIS COURT TO ORDER THE PREPARATION OF A FREE REPORTERS
RECORD ON APPEAL PURSUANT TO RULE 20.2 OF THE TEXAS RULES OF
APPELLANT PROCEDURE/ AND FOR GOOD CAUSE SHOWS THE FOLLOWING:
1. BRIAN TAYLOR GAVE WRITTEN NOTICE OF APPEAL FROM THIS JUDGMENT
OF CONVICTION ON MARCH 18th 2014. ATTHE SAME TIME, BRIAN TAYLOR
DESIGNATED CERTAIN MATTERS TO BE INCLUDED IN THE REPORTERS RECORD
AND CLERKS RECORD.
2. UNDER RULE 20.2 OF THE TEXAS RULES OF APPELLANT PROCEDURE,
"THE COURT MUST ORDER THE REPORTER TO TRANSCRIBE THE PROCEEDINGS"
IF THE APPELLANT CANNOT PAY OR GIVE SECURITY FOR THE APPELLANT
RECORD. "INDIGENCY" IS A MATTER OF THE APPELLANTS FINANCIAL STATUS
AT THE TIME OF APPEAL NOT AT THE TIME OF TRIAL." ZANGHETTI VS.
STATE/ 582,S.W. 2d. 461(TEX.CRIM. APP.(1979). RAMADAN VS. STATE
89,.,S.W. 3d. 744 (TEX APP. HOUSTON 2002).
PETITIONER, HEREIN ASSERTS THAT HIS FEDERAL AND STATE CONST
ITUTIONAL GUARENTEED RIGHTS WERE VIOLATED DURING THE PROSECUTION
OF THE ABOVE NUMBERED CAUSE, AND WITHOUT THE DOCUMENTS AND
RECORDS OF SAID PROCEEDINGS, PETITIONER CANNOT PREPARE A PLEADING
BY WAY OF HABEAS CORPUS PETITION IN WHICH TO SEEK RELIEF. PRAYER.
WHEREFORE, PREMISES CONSIDERED, PETITIONER PRAYS THIS HONORABLE
COURT WOULD GRANT THIS MOTION FOR A FREE REPORTERS RECORD ON
APPEAL AND SO ORDER THE CLERK, TO MAKE AND PREPARE A TRUE AND
CORRECT COPY IN PAPER FORM ON THE GROUNDS THE APPELLANT CANNOT
RECEAVE ELECTRONICALLY DOCUMENTS. AND ANY OTHER RELIEF THE COURT
FINDS DEEM.
RESPECTFULLY SUBMITTED
JRIAN TAYLOR APPELLANT TDCJ#1919122 BILL CLEMENTS UNIT 9601 SPUR 591 AMARILLO TEXAS 79107
INMATE DECLARATION
I BRIAN TAYLOR TDCJ#1919122 BEING PRESENTLY INCARCERATED IN THE
BILL CLEMENTS UNIT OF TEXAS DEPARTMENT OF CRIMINAL JUSTICE IN
POTTER COUNTY TEXAS VERIFY AND DECLARE UNDER PENALTY OF PERJURY
THAT THE ABOVE AND FORGOING STATEMENTS ARE TRUE AND CORRECT.
EXECUTED THIS /// DAY OF ^NOVEMBER Jif- CERTIFICATE OF SERVICE
THIS IS TO CERTIFY THAT A TRUE COPY OF THE FORGOING INSTRUMENT
TOGETHER WITH THIS PROOF OF SERVICE HEREOF HAS BEEN SENT TO THE
CLERK OF THE COURT OF CRIMINAL APPEALS AT PO BOX 12308 CAPITOL
STATION AUSTIN TEXAS 78711 BY U.S MAIL WITH FIRST CLASS POSTAGE.
ON THIS 14 DAY OF NOVMBER 2015.
PETITIONER
BRIAN TAYLOR TDCJ# 1919122