NO. 2016-CR-9470

STATE OF TEXAS					                     IN THE DISTRICT COURT

VS. 						      	                     227TH JUDICIAL DISTRICT

VICTOR JAVIER CRUZ TORRES                                          BEXAR COUNTY, TEXAS

REQUEST FOR PREPARATION OF REPORTER'S RECORD
AND DESIGNATION OF MATTERS TO BE INCLUDED

TO THE CLERK AND COURT REPORTER OF SAID COURT:

Now comes Victor Javier Cruz Torres, Defendant in the above styled and numbered cause, and pursuant to Rule 34.6(b) of the Texas Rules of Appellate Procedure, requests the court reporter or reporters who made the record in this cause to prepare a reporter's record, and that the testimony included in the reporter's record be in question and answer form. 
The plea hearing was held on January 22, 2018, before Hon. Raymond Angelini. The sentencing hearing was held on February 26, 2018, Hon. Kevin O’Connell. The court reporter at both hearings was Carol Castillo. The Defendant designates that the following matters be included in the reporter's record, if they exist:
1.	Testimony of all witnesses, heard in and outside the jury's presence, including questions and objections of counsel and the ruling and remarks of the Court thereon;
2.	Voir dire of jury venire, including objections of counsel and the ruling and remarks of the Court thereon;
3.	Arguments and opening and closing statements of counsel, including objections of counsel and the ruling and remarks of the Court thereon;
4.	All matters heard outside the presence of the jury, including pre-trial, trial and post-trial hearings, charge conferences and bench conferences, objections, rulings, and remarks of the Court thereon;
5.	All bills of exception and testimony thereon, including exhibits, objections of counsel, and the ruling and remarks of the Court thereon;
6.	Testimony taken during sentencing proceedings, including arguments and objections of counsel, and the ruling and remarks of the Court thereon;
7.	Testimony taken during motion for new trial proceedings, including arguments and objections of counsel, and the ruling and remarks of the Court thereon; and
8.	All exhibits admitted into evidence
9.	All exhibits offered into evidence but not received into evidence.
WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that this Court grant this request, and order preparation of the reporter's record in this case.
Respectfully submitted,

						/s/ Michael D. Robbins
						____________________________________
	 					MICHAEL D. ROBBINS.
						Assistant Public Defender
 						Paul Elizondo Tower
						101 W. Nueva St., Suite 370	
						San Antonio, Texas 78205
						(210) 335-0701
						Fax: (210) 335-0707
						mrobbins@bexar.org 
						Bar No. 16984600
						ATTORNEY FOR DEFENDANT	

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument has been emailed to: (1) the Bexar County District Attorney’s Office, Appellate Division, Paul Elizondo Tower, 101 W. Nueva St., Suite 710, San Antonio, Texas 78205; shameka.roberts@bexar.org; and (2) Ms. Carol Castillo, CSR, Cadena-Reeves Justice Center, 300 Dolorosa St., 4th Floor, San Antonio, Texas 78205, carol.castillo@bexar.org; on April 4, 2018.

 						/s/ Michael D. Robbins
 						____________________________________
						MICHAEL D. ROBBINS
						Assistant Public Defender