# Allen, Lynwyatt > Court of Appeals of Texas · September 30, 2015 URL: https://www.frixlaw.com/law-library/cases/4069928 ## Case - **Court:** Court of Appeals of Texas - **Decided:** September 30, 2015 - **Precedential status:** Published - **Opinion:** Opinion - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4069928 ## Opinion text WR-83,448-01,02,03 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/29/2015 5:55:11 PM Accepted 9/30/2015 10:23:29 AM ABEL ACOSTA CLERK CAUSENO.WR-83-448-01 RECEIVED CAUSE NO. WR—83-448-02 COURT OF CRIMINAL APPEALS 9/30/2015 CAUSE NO.WR-83-448-03 ABEL ACOSTA, CLERK IN THE COURT OF CRIMINAL. APPEALS AUSTIN. TEXAS IN THE MATTER OF THE WRITS OF HABEAS CORPUS FILED BY LYNWYATT ALLEN REQUEST FOR LEAVE TO FILE MOTION FOR COURT TO VACATE ITS ORDER DENYING WRIT AND REMAND FOR EVIDENTIARY HEARING IN THE ALTERNATIVE REQUEST FOR COURT TO VACATE ITS ORDER DENYING APPLICANTS PETITION AND REMAND FOR EVIDENTIARY HEARING ON ITS OWN MOTION. Cause arising out ofthe I86"‘ District Coun, Bexar County. Texas The Hon. Jefferson Moore, Presiding KENNETH ERIC BAKER SBN #2404543‘) "OfCounseI“ to DiazIakob. Attorneys L.L.C. Alamo Towers North 901 N.E. Loop 410 Suite 900 San Antonio, Texas 78209 (.210)226-4500 (p) (210) 226-4502 (f) TO THE HONORABLE COURT: Relief reguested: Reconsideration or the court’s denial of applicanfs Habeas Petition’s without hearing and remand for an evidentiary hearing. Procedural statement of the Case On March 18“‘, 2015, Applicant, Lynwyatt Allen, filed an application for a Writ of Habeas Corpus pursuant to Article 11.07 of the Texas Code of Criminal Procedure. (Exhibit AB &C) alleging ineffective assistance of counsel. On March 23"‘, 2015 the trial court entered an Order 011 Application for Post Conviction Relief (Exhibit D). The court found that there were controveited issues that “create a necessity for a hearing, but that the matter is capable of resolution by affidavit”. The court ordered trial counsel to submit an affidavit confirming or denying the allegations by May 7”‘, 2015 and further directed that trial counsel serve the undersigned post-conviction counsel with a copy of the affidavit (trial counsel’s affidavit attached as exhibit E). Simultaneously the court issued an Designating Issues (Exhibit F) finding that the issue of ineffective assistance of counsel required resolution. Trial counsel failed to serve the undersigned counsel until March 20"‘, 2015 (trial counsel’s letter to the undersigned is attached as Exhibit G). 10 days later the court issued an QlgI_er_ and Conclusions of Law (Exhibit H) recommending relief be denied based on the statement that trial counsel “sufficiently rebuts all allegations made against him”. This court issued an order denying applicant’s writs “on the findings of the trail court” (Exhibit I,J,K) Memorandum 1. Motions filed pursuant to art.11.07 or art. 11.071 of the Texas Code of Criminal Procedure and Rule 79.2gdt Counsel is aware of the limitations imposed by this foregoing rule and therefore asks the court to reconsider the denial sua spante based upon the issues and facts presented in this motion or request. 2. Due process requires an evidentiarv hearing to resolve controverted facts where it is the word of the defendant against the word of counsel; cross examination is foundational to get to the truth in matters where is the word of trial counsel against the word of the defendant. If a trial court finds there are controverted, previously unresolved facts material to the legality of applicant’s confinement, i.e., whether he received ineffective assistance of counsel, as the court in this matter did, then these issues shall be resolved in a timely manner: Coode of Criminal Procedure 11.07 art 3 (d): If the convicting court decides that there are controverted, previously unresolved facts which are material to the legality of the applicant's confinement, it shall enter an order within 20 days of the expiration of the time allowed for the state to reply, designating the issues of fact to be resolved. To resolve those issues the court may order affidavits, depositions, interrogatories, additional forensic testing, and hearings, as well as using personal recollection While this court gives deference to the manner in which a trial court gathers evidence due to the wide variety of claims made in Habeas applications, matters which can only be resolved by a credibility determination usually require a live hearing where the court can observe the witnesses and where the statements of the witnesses can be subjected to effective cross examination. This court often orders evidentiary hearings where the credibility of a witness in at issue. Ex Parre Brown, 205 SW. 3d 538 (Tex. Crim. App. 2006); Ex Pa/‘te Thompson, 153 S.W. 3d 416 (Tex. Crim. .App. 2005). This is particularly important in claims of ineffective assistance of counsel where trial counsel flatly denies the defendant’s allegations calling him a liar and responding with “not true” to each allegation of the defendant. (see Exhibit E). The 11'“ circuit stated the problem well in Gallego v. United States, 174 F.3d 1196 (1 1“‘ Cir. 1999) “Where issues come down to the testimony of the defendant against the contradictory testimony of counsel, the defendant is going to lose every time” Where there is a dispute between the client and the attorney over what occurred the trial court is required to make a credibility determination that can best be made after a live hearing. In Gallegos, the court pointed out that “magistrate does not even state simply why the defendant’s lawyer is the more credible witness in this case.” Based upon the foregoing the applicant though counsel respectfully requests this court remand the matter to the trial court for an evidentiary hearing where the completely contradictory statements of the applicant and trial counsel may be tested by cross examination and the trial court can make a credibility determination between the two. Respectfully submitted, By Kenneth Eric Baker SBN 24045439 Alamo Towers North 901 N.E. Loop 410, Suite 900 San Antonio, Texas 78209 210.226.4500 (P) 210.226.4502 (F) Keb1aw@gmail.com CERTIFICATE OF SERVICE This to certify that a true and correct copy of the foregoing Motion is was served upon the attorney for the State and on the Trial Court on September 29"‘. 2015. ‘ Attenfiey for Applicant Exhibit A . ' F ILEG. Case N°- ' ONNA KAY MEKINNEY’ _ msrmcr CLERK BEXAR COUNTY’ . . (The Clerk of the convicting court Wlll fill tlns line In.) INS MAR I ‘I A l|= 05 IN THE COURT OF CRIMINAL APPEALS OF TEXAS DEPUTY APPLICATION FOR A WRIT OF HABEAS CORPU§Y———V—-————~——T SEEKING RELIEF FROM FINAL FELONY CONVICTION UNDER CODE OF CRIMINAL PROCEDURE, ARTICLE 11.07 NAME: Lynwyatt Allen DATE OF BIRTH: 01/25/1991 PLACE OF CONFINEMENT: Dominguez State Jail 6535 Cagnon Rd, San Antonio, TX TDCJ-CID NUMBER: _01935579 SID NUMBER: 1001292 (1) This application concerns (check all that apply): xx a conviction N/A parole xx a sentence N/A mandatory supervision N/A time credit N/A out-of-time appeal or petition for discretionary review (2) What district court entered the judgment of the conviction you want relief from? (Include the court number and county.) 186“ District Court, Bexar County (3) What was the case number in the trial court? Cause No: 2013CR5726 (4) What was the name of the trial judge? Teresa Hen" Effective: Januag 1, 2014 1 (5) Were you represented by counsel? If yes, provide the attorney's name: Paul J. Goeke, SBN 08059250 (6) What was the date that the judgment was entered? 06/06/2013 (7) For what offense were you convicted and what was the sentence? Intoxication assault 10 yrs (8) If youwere sentenced on more than one count of an indictment in the same court at the same time, what counts were you convicted of and what was the sentence in each count? (9) What was the plea you entered? (Check one.) guilty-open plea _xx_ guilty-plea bargain not guilty nolo contenders/no contest If you entered different pleas to counts in a multi—count indictment, please explain: (10) What kind of trial did you have? NA no jury NA jury for guilt and punishment NA jury for guilt, judge for punishment (11) Did you testify at trial? If yes, at what phase of the trial did you testify? NA (12) Did you appeal from the judgment of conviction? _ yes xx no If you did appeal, answer the following questions: (A) What court of appeals did you appeal to? NA (B) What was the case number? NA (C) Were you represented by counsel on appeal? If yes, provide the attorney’s name: NA (D) What was the decision and the date of the decision? NA (13) Did you file a petition for discretionary review in the Court of Criminal Appeals? NA yes NA no If you did file a petition for discretionary review, answer the following questions: (A) What was the case number? NA (B) What was the decision and the date of the decision? NA (14) Have you previously filed an application for a writ of habeas corpus under Article 11.07 of the Texas Code of Criminal Procedure challenging this conviction? _ yes _xx_ no If you answered yes, answer the following questions: (A) What was the Court of Criminal Appeals’ writ number? (B) What was the decision and the date of the decision? (C) Please identify the reason that the current claims were not presented and could not have been presented on your previous application. (15) Do you currently have any petition or appeal pending in any other state or federal court? yes xx no If you answered yes, please provide the name of the court and the case number: (16) If you are presenting a claim for time credit, have you exhausted your administrative remedies by presenting your claim to the time credit resolution system of the Texas Department of Criminal Justice? (This requirement applies to any final felony conviction, including state jail felonies) yes xx no If you answered yes, answer the following questions: (A) What date did you present the claim? (B) Did you receive a decision and, if yes, what was the date of the decision? If you answered no, please explain why you have not submitted your claim: (17) Beginning on page 6, state concisely every legal ground for your claim that you are being unlawfully restrained, and then briefly summarize the facts supporting each ground. You must present each ground on the form application and a brief summary of the facts. Ifyour grounds and briefsummary ofthefacts have not been presented on the form application, the Court will not consider your grounds. If you have more than four grounds, use pages 14 and 15 of the form, which you may copy as many times as needed to give you a separate page for each ground, with each ground numbered in sequence. The recitation of the facts supporting each ground must be no longer than the two pages provided for the ground in the form. You may include with the form a memorandum of law if you want to present legal authorities, but theCourt will not consider grounds for relief set out in a memorandum of law that were not raised on the form. The citations and argument must be in a memorandum that complies with Texas Rule of Appellate Procedure 73 and does not exceed 15,000 words if computer-generated or 50 pages if not. If you are challenging the validity of your conviction, please include a summary of the facts pertaining to your offense and trial in your memorandum. GROUND ONE: Ineffective assistance of counsel FACTS SUPPORTING GROUND ONE: The attorney for Mr. Lynwyatt Allen (Defendant) pressured him into a plea. He was not prepared to go to trial. Just before trial a plea bargain was presented according to the following terms: An Application for deferred adjudication and probation could be made and a 15 year cap. The Attorney for the Defendant represented that no finding of a deadly weapon would be made and That the Defendant would receive deferred adjudication because he was “eligible”. The Defendant was actively mi-led by his attorney as to his application for probation being Granted as well as in the matter of no deadly weapon finding being made. If the attorney had properly advised the defendant that he might not receive deferred adjudication he would not have entered a no-contest plea. If the defendant’s attorney had told the defendant that a deadly weapon finding would be made he would not have entered his plea. I was specifically told there would be no finding of a deadly weapon GROUND TWO: FACTS SUPPORTING GROUND TWO: N Vi A! /4 GROUND THREE: AH/L ‘(\' FACTS SUPPORTING GROUND THREE: GROUND FOUR: FACTS SUPPORTING GROUND FOUR: A//(L 13 GROUND: MA VI FACTS SUPPORTING GROUND: MA NW 15 WHEREFORE, APPLICANT PRAYS THAT THE COURT GRANT APPLICANT RELIEF TO WHICH HE MAY BE ENTITLED IN THIS PROCEEDING. VERIFICATION This application must be verified or it will be dismissed for non-compliance. For verification purposes, an applicant is a person filing the application on his or her own behalf. A petitioner is a person filing the application on behalf of an applicant, for example, an applicant=s attorney. An inmate is a person who is in custody. The inmate applicant must sign either the AOath Before a Notary Public@ before a notary public or the AInmate=s Declaration@ without a notary public. If the inmate is represented by a licensed attorney, the attorney may sign the AOath Before a Notary Public@ as petitioner and then complete APetitioner=s Information. @ A non-inmate applicant must sign the AOath Before a Notaiy Public@ before a notary public unless he is represented by a licensed attorney, in which case the attorney may sign the verification as petitioner. A non-inmate non-attorney petitioner must sign the AOath Before a Notary Public@ before a notary public and must also complete APetitioner=s lnformation.@ An inmate petitioner must sign either the AOath Before a Notary Public@ before a notary public or the AInmate=s Declaration@ without a notary public and must also complete the appropriate APetitioner=s Information.@ OATH BEFORE A NOTARY PUBLIC STATE OF TEXAS COUNTY OF Ecgg /A \£g,g_)/d~tu ‘rk 7.97.‘; Telephotézf 93 ” Lfgod Fax: 7'26 ' INMATE=S DECLARATION I, , am the applicant / petitioner (circle one) and being presently incarcerated in , declare under penalty of perjury that, according to my belief, the facts stated in the above application are true and correct. Signed on , 20 . Signature of Applicant / Petitioner (circle one) 17 Exhibit B HLEB MNNA KAY MSKINNEY Case No. DISTRICT CLERK I BEMR COUNTY - (The Clerk of the convicting court will fill this line in: MR A "=05 . 1315 IT IN THE COURT or CRIMINAL APPEALS OF TEXAS BEPUTY APPLICATION FOR A WRIT OF HABEAS CORPUS i3Y__.____,._______ SEEIGNG RELIEF FROM FINAL FELONY CONVICTION UNDER CODE OF CRIMINAL PROCEDURE, ARTICLE 11.07 NAME: Lynwyatt Allen DATE OF BIRTH: 01/25/1991 PLACE OF CONFINEMENT: Dominguez State Jail 6535 Cagnon Rd, San Antonio, TX TDCJ-CID NUMBER: _01935579 SID NUMBER: 1001292 (1) This application concerns (check all that apply): xx a conviction N/A parole xx a sentence N/A mandatory supervision N/A time credit N/A out-of—time appeal or petition for discretionary review (2) What district court entered the judgment of the conviction you want relief from? (Include the court number and county.) 186"‘ District Court, Bexar County (3) What was the case number in the trial court? Cause No: 2013CR5727 (4) What was the name of the trial judge? Teresa Herr Effective: Januagg 1, 2014 1 (5) Were you represented by counsel? If yes, provide the attorney's name: Paul J. Goeke, SBN 08059250 (6) What was the date that the judgment was entered? 06/06/2013 (7) For what offense were you convicted and what was the sentence? Intoxication assault 10 yrs (3) If you were sentenced on more than one count of an indictment in the same court at the same time, what counts were you convicted of and what was the sentence in each count? (9) What was the plea you entered? (Check one.) guilty-open plea _xx_ guilty—plea bargain not guilty nolo contemlere/no contest If you entered different pleas to counts in a multi-count indictment, please explain: (10) What kind of trial did you have? NA no jury NA jury for guilt and punishment NA jury for guilt, judge for punishment (11) Did you testify at trial? If yes, at what phase of the trial did you testify? NA (12) Did you appeal from the judgment of conviction? __ yes XX 110 If you did appeal, answer the following questions: (A) What court of appeals did you appeal to? NA (B) What was the case number? NA (C) Were you represented by counsel on appeal? If yes, provide the attorney's name: NA (D) What was the decision and the date of the decision? NA (13) Did you file a petition for discretionary review in the Court of Criminal Appeals? NA yes NA no If you did file a petition for discretionary review, answer the following questions: (A) What was the case number? NA (B) What was the decision and the date of the decision? NA (14) Have you previously filed an application for a writ of habeas corpus under Article 11.07 of the Texas Code of Criminal Procedure challenging this conviction? __ yes _xx_ no If you answered yes, answer the following questions: (A) What was the Court of Criminal Appeals’ writ number? (B) What was the decision and the date of the decision? (C) Please identify the reason that the current claims were not presented and could not have been presented on your previous application. (15) Do you currently have any petition or appeal pending in any other state or federal court? yes XX___ [10 If you answered yes, please provide the name of the court and the case number: (16) If you are presenting a claim for time credit, have you exhausted your administrative remedies by presenting your claim to the time credit resolution system of the Texas Department of Criminal Justice? (This requirement applies to any final felony conviction, including state jail felonies) __ yes XX [10 If you answered yes, answer the following questions: (A) What date did you present the claim? (B) Did you receive a decision and, if yes, what was the date of the decision? If you answered no, please explain why you have not submitted your claim: (17) Beginning on page 6, state concisely every legal ground for your claim that you are being unlawfully restrained, and then briefly summarize the facts supporting each ground. You must present each ground on the form application and a brief summary of the facts. Ifyour grounds and briefsummary of thefacts have not been presented on the form application, the Court will not consider your grounds. If you have more than four grounds, use pages 14 and 15 of the form, which you may copy as many times as needed to give you a separate page for each ground, with each ground numbered in sequence. The recitation of the facts supporting each ground must be no longer than the two pages provided for the ground in the form. You may include with the form a memorandum of law if you want to present legal authorities, but theCourt will not consider grounds for relief set out in a memorandum of law that were not raised on the form. The citations and argument must be in a memorandum that complies with Texas Rule of Appellate Procedure 73 and does not exceed 15,000 words if computer-generated or 50 pages if not. If you are challenging the validity of your conviction, please include a summary of the facts pertaining to your offense and trial in your memorandum. GROUND ONE: Ineffective assistance of counsel FACTS SUPPORTING GROUND ONE: The attorney for Mr. Lynwyatt Allen (Defendant) pressured him into a plea. He was not prepared to go to trial. Just before trial a plea bargain was presented according to the following terms: An Application for deferred adjudication and probation could be made and a l5 year cap. The Attorney for the Defendant represented that no finding of a deadly weapon would be made and That the Defendant would receive deferred adjudication because he was “eligible”. The Defendant was actively mi-led by his attorney as to his application for probation being Granted as well as in the matter of no deadly weapon finding being made. If the attorney had properly advised the defendant that he might not receive deferred adjudication he would not have entered a no—contest plea. If the defenda.nt’s attorney had told the defendant that a deadly weapon finding would be made he would not have entered his plea. I was specifically told there would be no finding of a deadly weapon GROUND TWO: FACTS SUPPORTING GROUND TWO: N \A M /4 GROUND THREE: .«H/‘« 1 \' FACTS SUPPORTING GROUND THREE: I\J\A« I [ GROUND FOUR: FACTS SUPPORTING GROUND FOUR: N1 ? 13 GROUND: IMA FACTS SUPPORTING GROUND: MR 14 N UL I5 WHEREFORE, APPLICANT PRAYS THAT THE COURT GRANT APPLICANT RELIEF TO WHICH HE MAY BE ENTITLED IN THIS PROCEEDING. VERIFICATION This application must be verified or it will be dismissed for non-compliance. For verification purposes, an applicant is a person filing the application on his or her own behalf. A petitioner is a person filing the application on behalf of an applicant, for example, an app1icant=s attorney. An inmate is a person who is in custody. The inmate applicant must sign either the AOath Before a Notary Public@ before a notary public or the Alnmate=s Declaration@ without a notary public. If the inmate is represented by a licensed attorney, the attorney may sign the AOath Before a Notary Public@ as petitioner and then complete APetitioner=s lnforrnation.@ A non—inmate applicant must sign the AOath Before a Notary Public@ before a notary public unless he is represented by a licensed attorney, in which case the attorney may Sign the verification as petitioner. A non—inmate non—attomey petitioner must sign the AOath Before a Notary Public@ before a notary public and must also complete APetitioner=s Information.@ An inmate petitioner must sign either the AOath Before a Notary Public@ before a notary public or the AInmate=s Declaration@ without a notary public and must also complete the appropriate APetitioner=s Information.@ OATH BEFORE A NOTARY PUBLIC STATE OF TEXAS W ~ COUNTY OPE; E }_Q_I;K #45114 (,fL being duly sworn, under oath says: AI am ,.—. , the applicant / u (circle one) in this action and know the contents of the above application o ' for a writ of habeas corpus and, according to my belief, the facts stated in the plication are true.@ ~ Signatur of one) SUBSCRIBED AND SWORN TO BEFORE ME THIS “DAY OF ESQVC/l\ 20 .-ST.‘ ~ , [ 1 ~~ "'~’.,$’,‘..{\‘-*‘ moum ALBERIO TORANZO. Notary Public, Stove of lexos My Commission Expires June 17. 2018 JR. ‘ ” Slgnature of ’ Otary ’ P Bhc ‘ 16 PETITIONER=S INFORMATION Petitioner=s printed name: My ,J A) L114 EC \¢Q/ State bar number, if applicable: ‘i 3 6‘ Address: i S TFWJ *5 3+ 4*‘ 337 S»! \>£S'ld0'[£11\ Applicant’s right to appeal rulings on pretrial motions. In response to have structured the plea to appeal the motion to suppress, the prosecutor supplemented the stipulations in a way he believed would defeat such an appeal. That avenue was not pursued then, due to the pendency of the above described credit for time sewed. However, it should have been raised in this writ of Habeas Corpus by seeking an out of time appeal in that regard, as that issue would in my opinion have a high likelihood of success, certainly higher than that of patently absurd claim of ineffective assistance of counsel. The Applicant’s post-conviction pursuits would have been better placed in that regard and why that has been abandoned is beyond me except for Applicant’s acting pro se and without competent legal advice in this regard. I had previously advised Applicant and his family of the post-conviction strategy of seeking an out of time appeal challenging the denial of the motion to suppress. I had explained that Applicant could file a motion for a new trial and/or give notice of appeal regarding the motion to suppress the ruling. i also explained that doing so might draw attention to the unauthorized credit for time served and caused an interested prosecutor to challenge this credit. There also remained the possibility of the trial court reconsidering the deadly weapon finding by removing or omitting it in the judgment. As it developed, the trial court amended the judgment by awarding credit for time served. Judge Herr actually did this after herjurisdiction had expired in a manner which could now (and then) be challenged as invalid. Unfortunately, the affimtative finding of the use of a deadly weapon remained. The better strategy for Applicant would have been to employ experienced counsel and seek an out of time appeal of motion to suppress through a post-conviction writ of habeas corpus, a strategy which is probably now foreclosed by the “one writ rule”. By acting pro se and not following my advice, he has (I) lost legitimate challenge to his conviction and (2) threatened the continuing viability for his unauthorized credit for time served. If the prosecution now challenges that credit for time served, he will probably lose it. Additionally, he will not be able to challenge the trial court’s erroneous denial of his motion to suppress the warrantless blood draw, thus ruling out any further challenge to his sentence.” CONCLUSIONE OF LAW SI'BZ'LT,90 1. Under the two-prong standard for reviewing ineffective assistance of counsel claims, Applicant must show that (1) counsel’s representation fell below an objective standard of reasonableness and (2) there is a reasonable probability that, but for counsel’s deficient 09S'[d-@T£I;r’\ performance, the result of the proceeding would have been different. Strickland v. Washington, 466 U.S. 668 (1984); See also McFarland v. State, 845 S.W.2d 824, 842-43 (Tex. Crim. App. 1992). Trial counsel sufficiently rebuts all allegations made against him and provided a detailed account of his work on the case, the court concludes that his representation of Applicant did not below an objective standard of reasonableness. Therefore, this court ,1’ r—— recornrnends that Applicant’s second, third and fourth grounds for relief pertaining to ineffective assistance of counsel be DENIED. See Strickland v. Washinglon, 466 U.S. 668 (1984). Based on the foregoing findings of fact and conclusions of law, it is hereby recommended that this application be DENIED. SI!‘-)ZI1‘9(-J 0RDERS IA‘ The District Clerk of Bexar County, Texas, is hereby ordered to prepare a copy of this 15 document, together with any attachments and forward the same to the following persons by mail or the most practical means: T9SId‘E) a. The Court of Criminal Appeals Austin, Texas 78711 b. Nicholas “Nico” LaHood Criminal District Attorney Cadena - Reeves Justice Center Bexar County, Texas 78205 c. Lynwyatt Allen TDCJ ID: 01935579 Dominguez Unit 6535 Cagnon Road San Antonio, Texas 78252 SIGNED, ORDERED and DECREED on / U //45% Z 0/5 F i1soN MOORE e l86TH Judicial District Court exar County, Texas Exhibit I 5.. v:m_O NVLQJ S-m$..8-m_>> co=mo__nEm .m..woo_o> m4> >>o._m_-.n._ Emu A:MU So£_>> X._. §>.o~\.mmo_2o~ _m:.. ._.w_3OO mo .ZOE._ :m_n_ AOHE__mo >._.Z3OO 29$ wm:__u:_.. ”Z._.._.>>z>._ mm_>cm 9 mmmpm: 28:: .zm._._> .m...moo> mo»_o >>O._m_-m_ tzoo .ZELmD> _mE X._. ;>.REmom:.~ ._.m3OO mo .ZOEL_ :mn_ AO,Em__M_O >._.ZDOO mmcficc Eomm nZ._.._.>>Z>._ mm_>vm B wmmnmc m—.oN:,E. .zm_._._> .9.8o._.ZDOO m> Cw U, mq_-m_ m> >m_zz_v_os_ A.m~$mo2c~ BE X._. <>.u._3Z xwmzo mo .ZOHH> om_mm_>:m_n_ .oz qoeE>>z>._ mm_>_om 8 mmmgmc w_ .6 .zm._._< mS~::. mE.r E3 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4069928. Public record. Not legal advice.