CAUSE NO. 17-CR-1105

STATE OF TEXAS	§	        IN THE DISTRICT COURT 
	§
vs.	§	        212TH JUDICIAL DISTRICT OF
	§	
________________________ 	§	        GALVESTON COUNTY, TEXAS

	DEFENDANT'S REQUEST FOR NOTICE

	________________________, DEFENDANT, makes the following requests for notice pursuant to the Texas Rules of Evidence:
	Other Crimes, Wrongs or Acts.  Pursuant to Rule 404 (b), Texas Rules of Evidence, Defendant requests the State to furnish his attorney of record with written notice of its intent to use at trial any and all evidence of other crimes, wrongs, or acts of the Defendant in addition to the crime of which Defendant stands accused.  Defendant requests no fewer than ten (10) days notice of same, together with a description of the same and the purpose for which the same will be offered.
	Prior Convictions.  Pursuant to Rule 609 (f), Texas Rules of Evidence, Defendant requests the State to furnish his attorney of record with written notice of its intent to use at trial any and all evidence of prior convictions of crimes of the Defendant and all other witnesses listed on the subpoena application filed by Defendant.  Defendant requests no fewer than ten (10) days notice of same, together with a description of the prior conviction or convictions intended to be proven.
	Punishment Evidence.  Pursuant to Art. 37.07 § 3 (a) and 3 (g), Code of Criminal Procedure, Defendant requests notice of the evidence the State intends to offer on punishment, including but not limited to the Defendant's prior criminal record, his general reputation, his character, an opinion regarding his character, the circumstances of the offense for which he is being tried, and all extraneous crimes or bad acts the State intends to offer on punishment.

						Respectfully submitted,
						THE THIESSEN LAW FIRM

						 
						By:	_____________________________
	MARK THIESSEN 
SBN:  24042025
mark@thetexastrialattorney.com
TALY JACOBS
							SBN:  24074476
							taly@thetexastrialattorney.com
CHRIS DENUNA
							SBN: 24092338
							chris@thetexastrialattorney.com
733 E. 12th ½ Street
							Houston, Texas 77008
							PH: (713) 864-9000
							FX: (713) 864-9006

						Attorneys for Defendant,
						________________________

CERTIFICATE OF SERVICE

	I hereby certify that a true and correct copy of the above and foregoing motion has been delivered to the Assistant District Attorney assigned to this case, on this the ______ day of ____________________, 20___.

					  _________________________________
					           	 MARK THIESSEN