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CLEEVENTS Pee Ea Ua ea ol Coe ee Se eee ee eee coca) Poe Chr hue ae eR Gen i ec EG) Ra ae Rac ee Cay Pata LURE ‘August 18-20 :: Standardized Field Sobriety Test Certification Course eee ee ree} Orne ESE URE w ne T areca ea LO PAE PTR CUC LS October 22-23 :: Course Directors :: Jani Maselli and David Ryan DOOD INSULT November 20 :: Course Director :: David Ryan Pere ied SPO eee apse eS een April 28-29, 2016 :: Course Director :: Jani Masell, David Ryan and David Schulman Eee VISIT US @ UDR OLR Cais Croce Ge. ae ce: Serer Sree ie) Sar ae US Se OS 14 19 23 26 36 41 43 :HCCLA Ethics: :CLE Events ‘A Word from our President by JoAnne Musick ning Warriors ‘HCCLA News Round Up 9: Welcome New Members 9: Check out the new 10:: HCCLA Banquet Photos 12:: Annual Crawfish Boil Photos :Rethinking the Jury by Clay S. Conrad Know When to Hold Them & Know When to Fold Them by Robert Pelton ‘Practice Pointers ‘A Running Q6A by Mark Bennet, Nicole DeBorde, Pat McCann, & JoAnne Musick 22:: Basic Traffic Stop Reconstruction Q Tate Williams, guest writer 24:: Controlling Chaos by JoAnne Musick 25 :: General Criminal Checklist ‘Defending Boating While Intoxicated Cases by Doug Murphy ‘Stanley Schneider : A Profile by Brandon Ball :Chess Corner : Appear Weak When You Are Strong by Tyler Flood CHCCLA Extras ‘Ad Rates / New Member Application [As we kick off another year for HCCLA, I find myselfin awe of the amazing members we have. Not only ae they serting cases for «tial and winning bur they are aso helping in major ways, Sarsh Wood has almost single-handedly set up and run the nation’s foremost mentorship program. She routinely matches lawyers with more experienced (dare I say older) lawyers for networking, mentoring, and trial training. She holds regular brainstorming sessions where she encourages members to bring cases, discuss issues and strategize for successful representation, ‘Tyler Flood has sec up a winning formula for CLE success, Over the pase yeat, he created che "winning warriors” format and put together all-star lineups fr training day and basi training. David Ryan has taken over this commirtee and has several upcoming CLE events in che works, Keep an eye on our website and Faccbook page for CLE updates such as NHTSA FSTs Lawyer ‘Training (Aug 18-20), the First Judge Wendell Odom Appellate Seminar (April 2016), Winning Warrior: Winning Women (October 2015), Training Day, our Annual Donald Davis: Managing the Practice (November 201), and mote! Additionally, ‘Troy McKinney continues out happy hour CLE series ‘Thuy Le, Jimmy Atdoin, Damon Parrish If, J. Julio Vela, and Justin’ Harris have cotally revamped our Reasonable Doubt ‘community television program to bring you weekly current events and special guests as they discuss our local criminal justice system. With a huge undertaking, chey strive to bring you and the publican insider's view inta the law. Phillip Gommels continues working with the courts and office of court administration on the implementation of an electronic vouchering system for appointed attorneys. He has provided valuable input and will continue to push for adequate service, easy ‘vouchers, and faster payment turnarounds ‘Mark Thiessen is continuing the tradition of planning the best ‘organizational social events in che state while he expands his service into other areas. Look for his continued leadership as he begins a regular column in The Defender snd more training for cour membership. ® rmowo : a word from our president po Anne Ws teh Mark Bennete cartes che weight of all on his shoulders as he stands ready co quickly help any member in need through our Tecal Serke Force, Rarely is he not the first ro arrive fora lawyer in need. Rarely does he not find a favorable solution to our daily problems. Ready to fight, he soften the voice of reason for judges ‘who might otherwise have taken a misstep against a zealous advocate As each ofthese folks works ctelessly fora better organization and a better bar, you should know your entire board is hard at work. ‘This year we have also been invited co participace in the Harris County Criminal Justice Coordinating Council, a group of stakeholders seeking to work together to improve our system from arrests to incarceration to rehabilitation and mote efficient courts The Council is currently working on a theee-year study of recidivism rates across 5 major Teas Counties: Harris, Bexar, ‘Tarrant, Dallas and EI Paso, The Council also addresses other important issues such as jail population, pre-cral release bonds and strategic planning. Our organization is continuing ¢o grow ata steady pace. With, that growth, comes more responsbilicy. A responsibility to our members; responsibility 0 che public; a responsibility to che bar, As this new year begins, our board is prepared for that responsibility. Our board will tackle, head-on, injustices in our system and seck co better our organization and our practices. Ie is time for you to join us. We need your guidance, wisdom, and. assistance. Come to our meetings, share your concems, and work wich us for a seronger voice Call us! Tweed vs! Like vs! Tosin ves! On gp ole school & ovat us! At hee if we can help yp HCPDO Diana Olvera and Ana Benavides heard the sweetest 2 words in the court house on ASAC= 0, 10%) and 59 true releases (persons with BAC < 0.10%)" The study cites 6 officers made 80 correct, classifications out of 97, for an 82% correct decision ‘The take away from the comparison between the highway and ‘marine studies is that the alphabet, hand pat, finger to nose, ‘and finger count exercises still have no reliability or validity as previously determined by the previous “studies”. Lastly, the Tegal limit in 1990 atthe time of this study was 0.10, not 0.08. Q VALIDATION OF SOBRIETY TESTS FOR THE MARINE ENVIRONMENT ‘This second study is another government sponsored and funded product of the Southem California Research Institute entitled ‘Validation of sobriety tests for the marine cnvironment.!2 The study was funded by the U.S, Coast Guard, and NASBLA.* ‘The study was conducted because lack of uniformity amongst ‘enforcement of BWI, BUI state to state, The study recognizes the difficulties of enforcing BWI. First, it is not illegal 10 drink while beating. Open containers are legal. Second, there ‘are no speed limits, 50 excessive speed is not necessarily @ ‘clue of impairment. Third, environmental conditions (wind, ‘water choppiness, and glare) can make it difficult to determine boaters impairment, Unlike in the roadside, there is no standardized battery used on water. The objective of this study, ‘was to develop sobriety tests that can be administered in the seated position to assist water patrol to detect impairment above 08." + SITE & TIMING - The site was Lake of the Ozarks in Central Missouri, particularly Osage Beach location. Data was collected from Friday, June 26, 2009 through Monday, September 7, 2009, on the expected busiest boating days of the summer: Friday, Saturday, Sunday and holidays. Shifts for the officers began at noon and lasted roughly 10-12 hours depending on demand."* hese CONTINUED :: defending boating Srey. aS) Beet ats Py oh et a hod ea on +s eke : D The standardized clues are used to assess the suspect's performance. D The standardized eriteria are employed to Interpret that performance. IF ANY ONE OF THE STANDARDIZED FIELD SOBRIETY TEST ELEMENTS IS CHANGED, THE VALIDITY IS COMPROMIZED™ The exact procedures and clues for each of the three seated sobriety exercises as set_forth in the NASBLA BUI Seated Battery wansition Training Course, Student Manual can be found in the addendum located on this link: -ps:/ \VwXXSXb6CaETKHa?dl-0 @ wesc @ Defenses @ LIMITATIONS OF SEATED BATTERY The seated batery manual acknowledges thatthe seated battery may not be appropriate for people with certain disabilities, such as: >D People with certain arm, shoulder oF elbow problems may not he sble to perform the tests, >> People missing a portion of an index finger. ‘or mote should not be administered the FTN If ebvious disabilities are observed which would significantly limit the subject's ability to perform one or more ofthe tess, it is best not to administer the tests in question." Q@MARINE ENVIRONMENT The marine environment, as acknowledged in both studies, has “.._ certain stressors [that] are present in the boating environment Which are not present on the highway...” The stressors inherent in boating are heat, spray, boat motion, vibration, and glare and ‘may cause boaters (whether intoxicated or sober) to perform poorly on field sobriety tests, These environmental conditions (vind, water choppiness, and glare) can make it difficult to determine boaters impairment The 1990 marine study was not conducted in as harsh of temperatures or general boating conditions that most boaters will endure, The military personnel in that study were only passengers on a boat for 90 minutes, They were young, fit, and ‘ostensibly veteran boaters not susceptible to seasickness of sea legs. Most importantly, they were not under the threat of arrest This manual recognizes the limitations ofthe standing battery of SFST in the marine environment. Specifically, “[w]hen activities {such as boating) disrupt a person's equilibrium: balance is polentally affected for a period of time following the activity_A ‘Somnmon phenomenon occurs, commonly referred to as “sea legs," ‘where a person feels unsure of their balance on shore, especially ‘flor riding in a boat for long periods, The USCG recommends allowing a waiting period onshore for at least 15 minutes before ‘administering the standing SFST battery.” ‘back up the 15 minute waiting period when it stated: to be additional research performed to thorough uautfy the effects of "sea [egs” op a person's cquilibrum.™ ‘The manual further sets forth that the seated battery must be administered ina reasonably safe and stable environment. [tis recommended to administer the seated battery in calmer waters, i.e. backwaters, coves, bays or stabilized on the shoreline in & location that minimizes significant boat movement.” @ LEGAL CHALLENGE TO DETENTION On a roadway stop, an officer can only stop a motorist when reasonable suspicion exists to be & law violation has been committed, Morcover, NHTSA. has determined that certain driving characteristics are visual cues of an intoxicated driver. In the marine environment, most states allow marine officers to conduct water safety checks without the reasonable suspicion requirement, Specifically in Texas, Tex. Parks & Wild, Code Ann. § 31.124 authorizes a certified marine officer to stop and board any vessel only for the purpose of ensuring compliance with the registration and safety requirements, ‘The Texas Court of Criminal Appeals rejected a constitutional challenge to section 31.124 under the Fourth Amendment so Jong as the intrusion with the boaters is minimal in seope because the search may only be directed at the safety items listed in the statute, Further, while the boat must cary several safety and registration items, only a brief visual inspection is necessary 10 determine compliance. See Schenckl v. State, 30 S.W.3d 412, 417 (Tex.Crim.App, 2012)(Meyers, J, Concurting opinion). In Texas, a peace officer or game warden must be a certified marine safety enforcement officer by the department to enforce any provision of Tex. Parks & Wild. Code Ann. § 31.121. An officer is only allowed to check a boater for the following DD The vessels certificate of number. Tex. Parks & Wild Code Ann. § 31.028 (certifieate of number shall be earied ‘on board vessel); ‘> Identification number and validation decal. Id. at § 31.032 {identification number and validation decal shall be painted ‘on or attached to side of vessel near bow): >> Manufacturer's identification number. Id. at § 31.043 (vessels ‘manufactured in Texas for sale and vessels sold, numbered or ttle in Texas shall carry manufacturer's hull identification ‘number clearly imprinted on structure of vessel or displayed ‘on plate permanently attached to vessel); DD Lights. fd. at § 31.064; > sound-producing devices 1. a § 31.065; >> Life preserving devices, lat § 31.066; >> Fire extinguishers. fd. at § 31.067; Flame arrester or backfire trap on carburetors of gasoline 7 8 engines, with the exception of outboard motors. Ta. at § 31.068; _D Ventilators for bilges of engine and fuel tank compartments, ‘with the exception of open boats. Id. at § 31.069; >D Exhaust water manifold or mufMler installed on engine. Hd. at § 31.070; and >> Rearview mirror (in certain circumstances where persons are being towed), Id at §31.071 Despite Texas and other states allowing random spot checks for ‘water safety inspections, the United States Coast Guard, on their ‘website, specifically acknowledges that they do not condone or adhere to this practice: ‘The Coast Guard will not conduct random spot checks, blockades or checkpoints to detect intoxicated operators, nor will any quota systems be employed. A boarding officer will directa recreational boater to submit to afield sobriety test and/or breath analyzer test only when he has a reasonable suspicion that an operator is intoxicated or when @ marine aceident has occurred. Further, the Arkansas Supreme Court found the state statute authorizing water safety checks—as it was enforced in this ‘particular case—did not pass constitutional muster Sergeant Tucker testified that, while he tried to stop and perform a safety check on as many vessels as he could in a given day, there was no plea and nothing to determine which boats he stopped. There were no specific, objective facts about Allen's vessel to indicate that society's legitimate interests required the seizure of Allen and his particular vessel. As the circuit court found, Allen's vessel was being Tegally operated in an unremarkable fashion. Sergeant ‘Tucker testified that he did not believe that he had “the unfettered diseretion to pull over any boat at any time for any reason that {he desired],” but only to perform a safety check. However, this means that whether the stop is proper depends only on the law-enforcement office's subjective assertion of his or her purpose when the Fourth Amendment requires objective fact supporting the stop or a plan embodying explicit, neutral limitations.As the cireuit court found, the practice of saety-check stops by law-enforcement offices in this case violates the Fourth Amendment Sce State of Arkansas v, Robert M. Allen, 2013 Ark. 35 (Arkansas Supreme Court, Feb. 7, 2013). ‘cvs @) defending boating while intoxicated cases case is an example of excellent lawyering. Every state has a statute in place allowing suspicionless water safety checks, Do not concede the stop in your ease is legal. Preparation and good cross-examination could potentially obtain the same outcome as in the Arkansas case, Lawyers are encouraged to review their state statutes to determine compliance to ensure that the detention of your client was legally permitted. @PuPlic INFORMATION ACT REQUESTS. Public Information Act roquests to determine whether a particular marine officer is a certified marine officer as required by statute is anecessity. In addition, most state marine officers are required to report ther water safety check reports to their governing body. These officers are also required to submit BWI offense reports and other arrest paperwork to their governing body for statistical analysis. It is incumbent upon lawyers to also submit public information act requests forall of this information. These reports are a treasure trove of helpful information and can demonstrate a lack of competence, habits and modus operandi of officers, repeated language from report to report, etc. There are also agency violation analysis reports that are helpful to learn mote about & particular marine officer, Lastly, comitied marine officers that take the NASBLA BUI seated Battery Transition Training Course take an examination. This examination if forwarded to NSABLA for grading to a key. If NASBLA determines an officer passed the exam, they forward a cetificale, A subpoena duces tecum or public information act request should be made to NASBLA forthe arresting officer's exam, @puplic INFORMATION ACT REQUESTS Most water safety patrols utilize some form of electronic audio/visual recording device. It is routine in Texas for game wardens to utilize float cameras affixed to their hats with wireless microphones. These on the boat scene videos are very telling of the observations made by the officers of our clients. These videos generally demonstrate the absurdity and ridiculousness of the seated bat ci @ wesc ALPHABET AND COUNTING EXERCISES WERE EXCLUDED Lis common for water safety patrol to ask our clients to say the alphabet and also count backwards. While these tasks can cause ‘our clients to trip up due to being nervous due to threat of arrests, they have not been determined to be reliable. The truth is, the seated battery is actually even more susceptible to scoring elues due to nervousness and threat of artes. QSEATED EXERCISES DO NOT PROVE IMPAREMENT e seated exercises do not prove impairment. Rather, the seated cises when a certain number of clues are exhibited pusport to ly “suggest” that a person has & BAC of above 08.” Rule 401, Texas Rules of Evidence provides: “Relevant ‘evidence’ means evidence having any tendency to make the ‘existence of any fact that is of consequence to the determination ‘of the action more probable or less probable than it would be without the evidence.” Any evidence thatthe state wants to offer Which arises out of the NASBLA methods, procedures, waining land scoring is not relevant to impairment because all that information is only relevant to blood alcohol concentration (BAC). Therefore, the seated exercise BAC evidence does nat hhave any tendency to make the issue of impairment any more or less probable than without evidence. This preclusion of BAC ‘evidence is required by Emerson v. State, $80 SW2d 759 (Tex. Crim. App. 1994). (no quantifying evidence allowed) Indeed, this no impairment correlation premise is admitted by NHTSA and NASBLA. In the 2000 Student Manual entitled ‘DWI Detection and Standardized Field Sobriety Testing”, at section VIII, at p4., it says, “laboratory research indicated that three years ago tests, when administered in a standardized ‘manner, were a highly accurate and reliable battery of tests for distinguishing BACs above 0.10°. ‘The manual does not correlate standardized field sobriety test performance to physical or mental impairment. ‘Moreover, the NHTSA study entitled "Development and Field ‘Test of Psychophysical Tests for DWI Arrest (March 1981)”, at p. 72, that “[t]he major objectives of this project have been to... assess in the field its feasibility and effectiveness when used by the police for estimating BAC...” Additionally the NHTSA study entitled “A Florida Validation Study of the Standardized Field Sobrioty Test (S.F.S.T.) Battery affirms the notion that the SFST results are “made strictly in terms of BAC" at p. 13. Finally, the NIISTA study entitled “A Colorado Validation Study of the Standardized Field Sobriety Test (SFST) Battery” (November 1995), says in pertinent part hat “...this defined strictly in terms of the BAC statute and does not speak to the more difficult question of the individual driver's impairment”, at p.3. Under Rule 402 of Texas Rules of Evidence, the NASBLA seated exercise evidence is not admissible because it is not relevant in an impairment prosecution, Alternatively, under Rule 403, Texas Rules of Evidence, even if it were relevant, its probative value is substantially outweighed by the danger of Unfair prejudice, confusion of the issues, or misleading the jury or by considerations of undue delay, or needless presentation of cumulative evidence. The seated battery is as unreliable in the marine environment as NHTSA determined they were in stable and level field environment, The only thing these seated exercises provide is an excuse to justify a further detention to transport a boater to land for further investigation, Defense lawyers need to read these studies and the manual to be prepared to challenge the fallacies EZ MONITORING AP aa lie Owned & Operated ORDERED TODAY INSTALLED TODAY Ce] ea lg Ankle Monitors Nadal) PN) aT) Tle CoC aL) AT CMU oer Ca) 713.228.3969 le Rae LCP Ake >: tacrley a LA by Brandon Ball Q: Where are you from? A: Schenectady, NY, bom and raised. I went to undergraduate at Alfred, University which is about 70 miles south of Rochester, NY. I left the state of New York in the summer 1971 to attend law school at St. Mary’s School of Law in San Antonio. Q: What brought you to San Antonio from the East Coast? A: I only applied to four law schools in the fall of 1970. Albany, American, Notre Dame, and Syracuse. All four schools rejected me. My advisor told me about St. Mary's and that they were looking to diversify their program with some Yankees, so I applied and was accepted. I packed my bags and moved to Texas, Q: When you started law school did you know you wanted (o practice eriminal defen ‘A: No. [had no idea what I wanted to do. But, in the spring of 1972, I went to the courthouse and watched Warren Bumett, one of the greatest lawyers in the history of Texas, try a murder case, It was fascinating. I hung on his every word; so did the jury. He was the center of attention, It was his courtroom. He commanded respect. The client's name was Kincaid, who coincidently enough, I represented on a separate matter about 15 years later. Q: What was your first job out of law school and how did it come about? ‘A: I took a course in law school on civil rights law or something like that, It was taught by Judge Cadena out of San Antonio. I wrote a paper on the due process rights of prisoners during prison disciplinary proceedings. Procunier ¥. Martinez had just come down from the Supreme Court. I ‘was told by Jerry Gilbson that if | was interested in prisoner's rights I should contact this guy he went to law school with who was in Huntsville working at the Texas Department of Corrections as Staff Council for Inmates. I sent in my resume and got the job. The first day of work my boss, Harry Walsh, told me I had a brief due in the Sth Circuit the next week. My fitst question to him was “what's the Sth Circuit?” The issue in the case had to do with a defendant being tried in front of the jury in jail clothes. While my case was pending in the Sth Circuit, the Supreme Court granted certiorari and addressed that very issue. Iwas licensed in October of 1974 and argued my case in the Sth Circuit in March of 1975. Over the 39 months I worked as staff council, I had six arguments in the Sth Circuit, one argument in the Texas Court of Criminal Appeals, and appellate cases in state and federal courts all over Texas, : Why do you say 39 months instead of three years? ‘A: Because that was my sentence: I spent 39 months in prison, : Why did you choose to start a practice in Houston? ‘A; [felt Houston was more open. There was more things happening here than in Dallas or San Antonio. The community was more vibrant and active (Q: What attorneys did you attach yourself to when you first moved to Houston? ‘A: Tassociated with Mark Vela and Terry Collins. I followed them around. | tried my first capital murder case with Terry Collins in 1978. Q: How did you go about first getting cases when you opened your practice? A: Various ways. I received a felony court appointment everyday. Anything that Mark or Terry didn’t want, they gave to me. I had a whole bunch of prostitution cases and ‘was representing various modeling studios. I was trying at least two cases a month. Back then whenever someone was, going to trial the newspaper would write a small blurb about it, So folks would see the cases I was trying and would contact me. Q: You just mentioned the fact that you were getting appointed to felony cases as a young attorney. You don’t sce that in the criminal defense bar in Houston area as much these days. Do you think that it’s a good thing that young attorneys aren’t being appointed to felony cases straight out of law school? ‘A: I don’t think young attomeys should be trying felony ceases. [did mainly appellate work my first three years after law school. So I was able to see the good and the bad from all of the records I had read. I knew what not to do, but [just wasn’t sure how to do it. It took me a while to learn how to transfer from reading a record to doing it in the courtroom. There is a distinct difference between trying a case for a not guilty verdict and trying a case to preserve error or panera Appear Weak When You Are Strong Bae ee when using our forces, we must seem inactive, when we are near we must appear far away, when we are far away we must make the opponent believe we are ‘near. Humble words and increased preparations Cee ee ae Violent language and driving forward as if to attack are signs that your opponent may retreat.” Sova Pee Soa Se ee eR ea ee Nea Ree eat secs Ser eg ete me es Serene etna rena catt chess. Many were designed to deceive his opponent and take advantages of opportunities that resulted from those coer The Sun Tzu book The Art of War teaches deception, Pere ee cree based on deception, using surprise maneuvers and using your opponent's psychological predispositions against hhim to gain tactical advantages. In chess and martial arts, attack by deception, is the attack ofthe master, We must surprise our opponent and catch them in the moment of Pesneenss This applies to trial. If you are prepared and know your case inside and out there will be at least one moment, one point in the case, one opportunity you can seize and take ee eee eae Ces you are unprepared, opportunities may present themselves ‘without you even being aware of them and you will not be perro es SEC eee Scere geen sme et reckless—in order to bring pressure at once upon the adversary’s morale.”...Bruce Lee ee sa ee ee ae esa Sieroter ner Pr eM ee eee en Se eer gue sat to-using the deficiencies to your advantage in tral ROR eRe ues Pre ene es ents rR eR Onn ee a) to suppress by written pre-trial motion. You can raise a motion to suppress at any time during ee secre cd Pr a cee ee OE (Tex. Crim. App. 1977) eee Reese rye renee meer kany ss eee eae a Sry ie sas tre Rt) Cea rt a SORE ay Ce US Perens Re RE sas Oa eee nT as have yet to have one goexactly as expected CONTINUED :: Chess COLPNETN vier sree rcs Appear Weak When You Are Strong Teen ee eee a Se aU eerste and ready to take advantage of the surprise opportunity, ern eC ee Re ae ae Eon There is no need to stick your chest out and talk loud and make a public show of confidence unless you want Pr ote enna reece ret usually isa signal that you are desperately trying to obtain rere ve ty ac Mec eS eo ec eee ey ‘weak defense case or 2) who are scared to go to trial Being a trial lawyer is the only way to do this job correctly. Poke oe ee ec ee Pee ec ae RRC ae attomeys to go to trial more often and reap the rewards of Pree oreo ae ee ce eed rece re eee eae eay ‘when in trial. Opportunities that would never be realized if the attomey did not thoroughly prepare for trial and ‘opportunities that would never be seen if the lawyer pleads ut a case when there is no risk in trying it. Ree ee eee ene Setar reek een metas sg the right opportunity and the right time to make use of Cee M Ne e ReUee ie a ag boasting beforehand about problem's you have found with ‘your opponent’s case. Telling your opponent about issues beforehand will cause you to lose the issues completely Seen See eg rome ee ee) out and keeping quiet about it and luring your opponent eee eee Orci ey unleash your attack, taking your opponent by surprise, To be successful in trial, why not prepare, prepare, prepare, then be quiet, appear unprepared and wait for your day of triumph, Don’t telegraph your level of confidence Bynes On If you study people you can pick up on so many cues that tell you everything you need to know. For example, during a break in trial the other day I was about to move to suppress the HGN (motion granted) and I asked the officer {n the hallway a question about it before we went back on Cece nonce neo accusingly at me and then stated, “I’m not supposed to Pee hemes carn) talk to the atforneys just not other witness but then I said “Thank you though, you just answered my question for me.” He was weak and was trying to appear strong. If Pecos tery rc eee ten ts Sone Nee core kere a nin The idea of being quiet and confident goes both ways though. The prosecutors I am most concemed about, the cones who I worry the most about, are not the ones emailing me or calling me asking me if I'am ready on a case. It's the ones who I ask if they are ready and they simply give Por CS Mm eg rect eee rece g for tril then I know they are not wanting to go to trial on that case for some reason, You can learn a lot by paying renters ss eee SO RM ee eS ee eee ears ‘opponent of all the work you have done in preparing for the trial and letting them know that you are very ready and very prepared will cause them to work harder and be even more prepared to fight you, Ifyou know for sure it isa trial case then consider following the ancient lessons ee Ree ec ees weak and unprepared and you can catch your opponent Seen re Tas usenet increase. This doesn't necessarily apply to cases that Sea Re Se CMR Tey es ne che Cece eee ney errata) Nene See ee Ree say place. Set your cases for trial and announce “Ready” on one o7.NaI ethics hotline 713°518°1738 ro An inheritance OnQnN, Bite Dauncy wie Ht Pons ha jet non haste, aoe eee ae EB--— sown Te ADRATES FULL PAGE [INSIDE] :: $700/ISSUE :: $2,520/YEAR INSIDE FRONT COVER :: $800/ISSUE =: $2,880/YEAR INSIDE BACK COVER :: $750/ISSUE :: $2,700NEAR BACK COVER :: SB00/ISSUE = $2,880/YEAR 2/3 PAGE :; $600/ISSUE :: $2, 160/YEAR 1/2 PAGE :; $S00/'SSUE :: $1,800/YEAR 1/3 PAGE :: $400/ISSUE :: $1,440/YEAR 1/4 PAGE :: $250/ISSUE :: $900/YEAR BUSINESS CARD SIZE :: $125/ISSUE = $450/YEAR Distribution 1000 copies per issue. For articles and other editorial contributions, contact JoAnne Musick at 832-448-1148. To place an ad contact Earl Musick 832-448-1148 / HCCLA MEMBERSHIP APPLICATION @ Applicant | Firm Name: Telephone number: Fax Mailing address: inal address: Website: Date admitted to practice: Would you like to join the HCCLA listserv? ‘Type of membership (dues) ___ Regular membership ($150*) Public Detender (State/Federal)($75*) — New criminal defense lawyer (within two years of beginning criminal defense practice) ($75*) Senior Member ($75*) aralegal Member ($50*) Student ($25) Expected graduation date: Date Signature of applicant Endorsement 1, a member in good standing of HCCLA, believe this applicant to be a person of professional competency, integrity and good moral character. The applicant is actively engaged in the defense of criminal cases. (For paralegals this applicant is employed by member in good standing) Date Signature of endorsing member PRINTED NAME OF ENDORSING MEMBER Mail this application to: HCCLA P.O. Box 924523 Houston, Texas 77292-4523, WTF paid between April 1 and December 31, this amount constitutes payment of dues until May 31 of the following year. Dues paid between January I and March 31 are half the listed amount and cover membership until May 31 of the SUMMER 2015 THE DEFENDER Pelee PO Box 92452 HOUSTON, TEXAS Houston TX 17292- 4523 PERMIT NO. 11500 BILACKWOOT) oo iy Epp BLACKWOOD ® LICENSE 74432 713-222-BAIL (2245) Houston’s Oldest (CGA RSaEnIREINTO Bail Bonding Company HOUSTON, TEXAS 77002 Serving Houston, WE ALSO PROVIDE : COURTROOM ASSISTANCE Harris County, All Texas counties, and Nationwide bail bonds

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