                                                                         ACCEPTED
                                                                     01-14-00722-CR
                                                          FIRST COURT OF APPEALS
                                                                  HOUSTON, TEXAS
                                                               6/25/2015 12:22:22 PM
                                                               CHRISTOPHER PRINE
                                                                              CLERK
            01-14-00722-CR
            ###########
        No. 01-14-00772-CR
                 In the                           FILED IN
          Court of Appeals                 1st COURT OF APPEALS
                                               HOUSTON, TEXAS
                For the
                                           6/25/2015 12:22:22 PM
    First Judicial District of Texas
                                           CHRISTOPHER A. PRINE
              At Houston                            Clerk

     
            No. 1384675
    In the 209th District Court of
        Harris County, Texas
     
      THANH KIM HOANG
               Appellant
                 v.
     THE STATE OF TEXAS
                Appellee
     
   STATE’S APPELLATE BRIEF
     
                                   DEVON ANDERSON
                                   District Attorney
                                   Harris County, Texas
                                   CARLY DESSAUER
                                   Assistant District Attorney
                                   NATHAN MOSS
                                   Assistant District Attorney
                                   Harris County, Texas
                                   1201 Franklin, Suite 600
                                   Houston, Texas 77002
                                   Tel.: 713/755-5826
                                   Fax No.: 713/755-5809

ORAL ARGUMENT NOT REQUESTED
              STATEMENT REGARDING ORAL ARGUMENT
      Pursuant to Texas Rule of Appellate Procedure 9.4(g) and Texas Rule of

Appellate Procedure 39.1, the State does not requests oral argument as the issue

involved in this appeal can adequately be determined from the record and established

law but wishes preserve its right to present oral argument if this Court desires to

submit this case through oral argument.

                     IDENTIFICATION OF THE PARTIES
      Pursuant to Texas Rule of Appellate Procedure 38.2(a)(1)(A), a complete list of

the names of all interested parties is provided below.

      Counsel for the State:
             Devon Anderson  District Attorney of Harris County
             Carly Dessauer  Assistant District Attorney on appeal
             Nathan L. Moss  Assistant District Attorney at trial
             David Bernard  Assistant District Attorney at trial
                   1201 Franklin Street, Suite 600, Houston, Texas 77002

      Appellant or criminal defendant:
             Thanh Kim Hoang

      Counsel for Appellant:
             Charles Hinton  Attorney on appeal
                   P.O. Box 53719, Houston, Texas 77052
             Kurt B. Wentz  Attorney at trial
                   5629 FM 1960, Suite 115, Houston, Texas 77069

      Trial Judge:
             Hon. Wayne Mallia


                                           ii
                                            TABLE OF CONTENTS
STATEMENT REGARDING ORAL ARGUMENT .................................................... ii
IDENTIFICATION OF THE PARTIES ......................................................................... ii
TABLE OF AUTHORITIES ............................................................................................. iv
STATEMENT OF THE CASE .......................................................................................... 1
STATEMENT OF FACTS .................................................................................................. 1
SUMMARY OF THE ARGUMENT ................................................................................. 3
REPLY TO APPELLANT’S POINT OF ERROR ......................................................... 3
I. The jury charge did not erroneously instruct the jury on the intent appellant
   needed to be a party to capital murder........................................................................... 3
     a. The jury charge correctly required that the jury only convict appellant as
        a party to capital murder if it found that he had the intent to promote or
        assist Bui in killing Tu................................................................................................. 6
     b. Assuming for the sake of argument that the jury charge was erroneous,
        appellant was not egregiously harmed by the instruction. ................................... 10
CONCLUSION ................................................................................................................... 13
CERTIFICATE OF COMPLIANCE .............................................................................. 14
CERTIFICATE OF SERVICE ......................................................................................... 15
APPENDIX .......................................................................................................................... 16




                                                                 iii
                                          TABLE OF AUTHORITIES

CASES
Almanza v. State,
  686 S.W.2d 157 (Tex. Crim. App. 1984) ................................................................... 4, 10
Holford v. State,
  177 S.W.3d 454 (Tex. App.—Houston [1st Dist.] 2005, pet. ref’d) ...................... 9, 10
Nelms v. State,
  No. 01-13-00689-CR, 2014 WL 3738065
  (Tex. App.—Houston [1st Dist.] July 29, 2014, pet. ref’d)
  (mem. op., not designated for publication)................................................................. 7, 8
Ngo v. State,
  175 S.W.3d 738 (Tex. Crim. App. 2005) ......................................................................... 4
Vasquez v. State,
 389 S.W.3d 361 (Tex. Crim. App. 2012) ...................................................... 4, 5, 7, 8, 12

STATUTES
TEX. CODE CRIM. PROC. ANN. art. 36.14 (West 2007) ...................................................... 5
TEX. PENAL CODE ANN. §7.01(a) (West 2011) .................................................................. 5
TEX. PENAL CODE ANN. §7.02(a)(2) (West 2011) .............................................................. 5
TEX. PENAL CODE ANN. §19.03(a)(2) (West Supp. 2014)................................................. 5
TEX. PENAL CODE ANN. §29.02(a) (West 2011) ................................................................ 5

RULES
TEX. R. APP. P. 9.4(g) ............................................................................................................. ii
TEX. R. APP. P. 9.4(i). ........................................................................................................... 14
TEX. R. APP. P. 38.2(a)(1)(A) ................................................................................................. ii
TEX. R. APP. P. 39.1 ................................................................................................................ ii




                                                                  iv
TO THE HONORABLE COURT OF APPEALS:

                             STATEMENT OF THE CASE
       Appellant was charged with capital murder (CR at 11). Appellant entered a

plea of not guilty and request a jury trial to determine guilt (CR at 96; 3 RR at 16).

The jury found appellant guilty, and since the State did not seek the death penalty, the

court assessed punishment at confinement for life without parole (CR at 112, 114; 5

RR at 37, 40). The court certified appellant’s right to appeal, and appellant filed a

timely notice of appeal (CR at 117-18).

                               STATEMENT OF FACTS
       Appellant and his co-defendant, Vu Bui, went to Tuan Tu’s game room and

café, Café Chieu Tim (3 RR at 24; 4 RR at 29). The two other patrons present,

brothers Nghiep and Johnny Le, were playing pool when they arrived (3 RR at 123,

125; 4 RR at 13, 14; State’s Ex. 43). Both brothers noticed the men as they were

strangers, and the brothers were used to seeing only regulars at the café (3 RR at 125;

4 RR at 15-16). Indeed, Johnny was uncomfortable with them because, in addition to

not knowing the men, they did not remove their jackets or sunglasses despite being

inside and the weather being hot (3 RR at 126; State’s Ex. 43). Appellant and Bui sat

down at a table and ordered iced coffee (3 RR at 126, 142; 4 RR at 16; State’s Ex. 43).1

After about thirty minutes of sitting, smoking, and occasionally talking with Tu,


1
 Appellant’s DNA could not be excluded from DNA found at the scene on a pair of glasses, a glass,
and a cigarette butt (3 RR at 39, 50; 4 RR at 66, 70; State’s 29, 58, 59).


                                               1
appellant and Bui walked up to the three men, and Bui pulled out a gun (3 RR at 127,

148; 4 RR at 17, 18; State’s Ex. 43).

       Bui tapped the gun on Johnny’s shoulder as he was facing the pool table and

was unaware of the unfolding robbery (3 RR at 129-30, 143). Appellant was at his

side, ready to assist Bui in controlling the men (3 RR at 131). Bui instructed them to

kneel, and appellant then told Johnny “to lay down” (3 RR at 130, 131, 149; 4 RR at

17, 18). However, Tu, who had a concealed handgun, drew his weapon to defend

himself and his business from appellant and Bui (3 RR at 69, 135). Tu and Bui

exchanged gunfire (3 RR at 135, 136; State’s Ex. 43). Bui shot at Tu until his gun was

empty, hitting Tu twice in the chest and killing him (4 RR at 52; State’s Ex. 43).

       Both Bui and appellant fled the scene (3 RR at 138). Appellant was later

apprehended by police, but at the time of trial, Bui had not yet been apprehended (3

RR at 79, 85).

       The evidence presented at trial established that Bui, not appellant, had fired the

fatal shots that hit Tu during their robbery, so the trial court instructed the jury that it

could find appellant guilty of capital murder as a principle, party, or co-conspirator to

the offense (CR at 97-103). APPENDIX. The court also instructed the jury on the

lesser included offenses of felony murder and aggravated robbery (CR at 103-106).

Appellant did not object to the charge at trial (4 RR at 101).




                                             2
                            SUMMARY OF THE ARGUMENT
           The trial court did not err when it instructed the jury on appellant’s requisite

     mental state to be guilty as a party to capital murder as the charge required the jury to

     find that appellant had the intent to promote or assist Bui with the robbery in addition

     to the intent to solicit, encourage, direct, aid, or attempt to aid Bui in shooting and

     killing Tu. Appellant’s argument focuses on one portion of the jury charge and

     ignores that the charge as a whole correctly stated the law regarding party intent.

     Analyzed as a whole, the court did not err in its charge, and appellant’s sole point of

     error should be overruled.

                     REPLY TO APPELLANT’S POINT OF ERROR
I.      The jury charge did not erroneously instruct the jury on the intent appellant
        needed to be a party to capital murder.

           In his sole point of error, appellant argues that the trial court erred in charging

     the jury on the law of parties when it instructed that before the jury could find

     appellant guilty of capital murder as a party, it “must find from the evidence beyond a

     reasonable doubt that [appellant] with intent to promote or assist in the commission

     of the offense of robbery, if any, solicited, encouraged, directed, aided, or attempted

     to aid Vu Bui in shooting Tuan Tu, if he did, with the intention of thereby killing

     Tuan Tu” (CR at 101). Appellant alleges that the instruction allowed the jury to find

     him guilty as a party if it only found that he had intent to promote or assist the

     robbery without also having the intent to promote or assist Tu’s murder. Appellant’s



                                                3
argument focuses on the phrase that instructed the jury that it must find that appellant

had the “intent to promote or assist in the commission of the offense of robbery” to

support his claim (CR at 101). However, as the language of the whole charge shows,

the court did not misinform the jury on appellant’s requisite intent as a party to capital

murder. The instruction, as a whole, correctly required that the jury had to find that

appellant had the intent to assist or promote Bui both in the robbery and in killing Tu.

As such, the court’s instruction was not erroneous.

                                 Standard of Review

      A reviewing court’s first duty in analyzing a jury-charge issue is to decide

whether error exists. Ngo v. State, 175 S.W.3d 738, 743 (Tex. Crim. App. 2005). When

examining the charge for possible error, reviewing courts “examine the charge as a

whole instead of a series of isolated and unrelated statements.” Vasquez v. State, 389

S.W.3d 361, 366 (Tex. Crim. App. 2012) (quoting Dinkins v. State, 894 S.W.2d 330, 339

(Tex. Crim. App. 1995)).

      Only if the court finds error, it must then conduct a harm analysis depending

on whether the appellant objected to the error. Ngo, 175 S.W.3d at 743. When a

defendant does not object to the court’s charge, the reviewing court can only reverse

if the defendant suffered egregious harm. Almanza v. State, 686 S.W.2d 157, 171 (Tex.

Crim. App. 1984).




                                            4
                                  Applicable Law

      A trial court must instruct the jury on the “law applicable to the case” when

charging the jury. TEX. CODE CRIM. PROC. ANN. art. 36.14 (West 2007). “Because

the charge is the instrument by which the jury convicts, [it] must contain an accurate

statement of the law and must set out all the essential elements of the offense.”

Vasquez, 389 S.W.3d at 366 (quoting Dinkins, 894 S.W.2d at 339).

      A person commits the offense of capital murder if he intentionally or

knowingly causes the death of an individual in the course of committing or attempting

to commit robbery. TEX. PENAL CODE ANN. §19.03(a)(2) (West Supp. 2014). A

person commits robbery if, in the course of committing theft and with intent to

obtain or maintain control of property, the person intentionally, knowingly, or

recklessly causes or threatens bodily injury to another. TEX. PENAL CODE ANN.

§29.02(a) (West 2011).

      “A person is criminally responsible as a party to an offense if the offense is

committed by his own conduct, by the conduct of another for which he is criminally

responsible, or by both.” TEX. PENAL CODE ANN. §7.01(a) (West 2011). To be

criminally responsible for an offense committed by the conduct of another, the

person must act with the intent to promote or assist the commission of the offense by

soliciting, encouraging, directing, aiding, or attempting to aid the other person to

commit the offense. TEX. PENAL CODE ANN. §7.02(a)(2) (West 2011).




                                          5
                                         Analysis

   a. The jury charge correctly required that the jury only convict appellant as
      a party to capital murder if it found that he had the intent to promote or
      assist Bui in killing Tu.

       In its instruction, the trial court charged the jury that it could find appellant

guilty as a principle, as a party, and as a co-conspirator to the offense of capital

murder (CR at 97-103). APPENDIX. Regarding the law of parties, the court first

defined criminal responsibility as a party for the jury:

       A person is criminally responsible for an offense committed by the
       conduct of another if, acting with intent to promote or assist the
       commission of the offense, he solicits, encourages, directs, aids, or
       attempts to aid the other person to commit the offense (CR at 100-01).

The court then gave the jury an instruction involving the law of parties and appellant’s

charged capital murder:

       Before you would be warranted in finding [appellant] guilty of capital
       murder, [… ] you must find from the evidence beyond a reasonable
       doubt that [appellant], with the intent to promote or assist in the
       commission of the offense of robbery, if any, solicited, encouraged,
       directed, aided, or attempted to aid Vu Bui in shooting Tuan Tu, if he
       did, with the intention of thereby killing Tuan Tu (CR at 101).

Finally, the court gave the jury an application paragraph applying the law of parties to

the facts of appellant’s charged capital murder:

       If you find from the evidence beyond a reasonable doubt that on or
       about the 8th day of February, 2013, in Harris County, Texas, Vu Bui,
       did then and there unlawfully, while in the course of committing or
       attempting to commit the robbery of Tuan Tu, intentionally cause the
       death of Tuan Tu by shooting Tuan Tu with a deadly weapon, namely a
       firearm, and [appellant], with the intent to promote or assist the


                                             6
      commission of the offense, if any, solicited, encouraged, directed, aided
      or attempted to aid Vu Bui to commit the offense, if he did[…] then you
      will find the defendant guilty of capital murder, as charged in the
      indictment (CR at 102-03).

      As is evident from the charge as a whole, the trial court did not erroneously

instruct the jury on the law of parties in a way that would have allowed the jury to

convict appellant of capital murder if it only found that he had the intent to promote

or assist the commission of the offense of robbery as appellant alleges on appeal. See

Vasquez, 389 S.W.3d at 366 (requiring reviewing courts to review the jury charge as a

whole). As the charge stated in the paragraph appellant claims to be erroneous, the

jury could only find appellant guilty of capital murder if it found that appellant had

both the “intent to promote or assist in the commission of the offense of robbery” and

“solicited, encouraged, directed, aided, or attempted to aid Vu Bui in shooting Tuan

Tu, if he did, with the intention of thereby killing Tuan Tu (CR at 101) (emphasis added).

The charge did not omit the requisite intent to kill as appellant claims.

      Indeed, the jury charge in appellant’s case is nearly identical to the charge

recently analyzed by this Court in Nelms v. State. Nelms v. State, No. 01-13-00689-CR,

2014 WL 3738065, at *2 (Tex. App.—Houston [1st Dist.] July 29, 2014, pet. ref’d)

(mem. op., not designated for publication). Nelms, like appellant, was convicted of

capital murder; however, the aggravating element of his offense was the offense of

burglary of a habitation. Nelms, 2014 WL 3738065, at *2. Nelms, like appellant,

complained that the jury charge erroneously allowed the jury to find him guilty as a


                                            7
party to capital murder if it found that he had the intent to be a party to the

aggravating offense when it instructed the jury that “you must find from the evidence

beyond a reasonable doubt that [Nelms], with the intent to promote or assist in the

offense of burglary of habitation.” Nelms, 2014 WL 3738065, at *3 (italics in original).

Nelms, like appellant, argued that the correct instruction should have told the jury that

his intent to promote or assist should have been directed towards the offense of

capital murder instead of his aggravating offense of burglary of a habitation. Nelms,

2014 WL 3738065, at *3. However, appellant, like Nelms, failed to consider the

charge as a whole when making his argument. Nelms, 2014 WL 3738065, at *3 (noting

that jury charge also instructed the jury that it must find that Nelms “solicited,

encouraged, directed, aided, or attempted to aid [Jones] in shooting [Nelson], if he

did, with the intention of thereby killing [Nelson ]”) (italics in original).

       For the same reason that this Court rejected Nelms’ argument, this Court

should likewise reject appellant’s identical argument after analyzing the charge as a

whole. See Vasquez, 389 S.W.3d at 366. The court’s entire jury charge involving

appellant’s guilt on theory of the law of parties correctly informed the jury that

appellant needed the intent to promote or assist Bui with the robbery as well as the

intent to promote or assist Bui in killing Tu before it could find appellant guilty of

capital murder as a party (CR at 101, 102-03). See Nelms, 2014 WL 3738065, at *3.

The sentence that appellant focuses on in his argument does mention that appellant

intend to promote or assist the offense of robbery, but the court’s instruction goes on

                                                   8
to state that appellant also needed the intent to solicit, encourage, direct, aid, or

attempt to aid Bui in shooting Tu to be criminally responsible as a party to capital

murder (CR at 101). Additionally, the application paragraph set out similar language

as the sentence appellant focuses on in his brief but does not designate the offense of

robbery to be the offense appellant had to intent to commit (CR at 102-03). Instead,

the court instructed the jury that it could find appellant guilty only if it found beyond

a reasonable doubt that appellant intended “to promote or assist the commission of

the offense” (CR at 102-03).

       In Holford v. State, this Court upheld the jury charge over Holford’s claim that

the charge allowed the jury to convict him as a party to capital murder if he intended

to aid only in the robbery when the application paragraph “cautioned the jury” that it

must also find intent to kill. Holford v. State, 177 S.W.3d 454, 460, 461 (Tex. App.—

Houston [1st Dist.] 2005, pet. ref’d) (noting that the jury charge read: “Before you

would be warranted in finding the defendant guilty of capital murder, ... you must find

from the evidence beyond a reasonable doubt that the defendant, David Charles

Holford, with the intent to promote or assist in the commission of the offense of robbery, if any,

solicited, encouraged, directed, aided, or attempted to aid Harold Louis Vaughn in cutting or striking

Trevor Cook, if he did, with the intention of thereby killing Trevor Cook”) (italics in original).

In Holford, this Court noted that, when “read logically,” “the clause “solicited,

encouraged, directed, aided or attempted to aid Harold Louis Vaughn to commit the

offense” refers to the complainant’s murder. Holford, 177 S.W.3d at 461. The same

                                                  9
logical reading applies to the party instruction in appellant’s charge in which the clause

“solicited, encouraged, directed, aided, or attempted to aid Vu Bui in shooting Tuan

Tu” refers to Tu’s murder (CR at 101).

      Because the charge as a whole directed the jury that it needed to find that

appellant had the intent to kill Tu before it could find him guilty as a party to capital

murder, the court’s charge is not erroneous. Therefore, this Court should overrule

appellant’s argument.

   b. Assuming for the sake of argument that the jury charge was erroneous,
      appellant was not egregiously harmed by the instruction.

      Assuming for the sake of argument that the trial court’s charge erroneously

instructed the jury regarding the required intent appellant needed to be guilty of

capital murder as a party, appellant’s conviction does not require reversal. Almanza,

686 S.W.2d at 171 (requiring that the defendant who does not object to the court’s

charge at trial to suffer egregious harm to obtain a reversal). Had the trial court’s

charge on party intent been erroneous, appellant, who did not object to the court’s

charge at trial, was not egregiously harmed by the jury instruction (4 RR at 101).

                                 Standard of Review

      To determine whether a defendant has sustained egregious harm from a jury

instruction, the reviewing court considers (1) the entire charge; (2) the state of the

evidence, including contested issues; (3) arguments of counsel; and (4) any other

relevant information. Holford, 177 S.W.3d at 461.


                                           10
                                          Analysis

      The jury charge did not egregiously harm appellant because, not only did the

charge correctly instruct the jury correctly on the law of parties, the court also

instructed the jury that appellant could be guilt as the primary actor or as a

conspirator to the offense. While the evidence would not have supported appellant’s

conviction as a primary, the evidence proved beyond a reasonable doubt that

appellant was guilty as a party as well as a co-conspirator, and the jury could have

found him guilty under either theory.

      Eyewitness testimony, surveillance video, and DNA evidence put appellant at

the scene of the offense (3 RR at 39, 50, 125-26; 4 RR at 13, 66, 70; State’s 29, 40; 43,

58, 59). The evidence showed that appellant and Bui entered the café together and

that they did not need to tell each other what they were doing when they initiated the

robbery, inferring prior planning (3 RR at 123, 125, 127, 147-48; 4 RR at 18). The

evidence established that appellant acted in concert with Bui by following him, ready

to provide assistance when Bui threated Tu and the Le brothers with his loaded gun,

and appellant instructed the robbery victims to comply with their demands (3 RR at

129-31). Indeed, Johnny testified that when Bui placed his gun on his shoulder,

appellant instructed him to lay down on the ground (3 RR at 149). Further, both Le

Brothers testified that appellant was not surprised or afraid when Bui pulled out his

gun (3 RR at 147, 149; 4 RR at 19, 20).




                                            11
      The arguments of counsel also establish that appellant was not egregiously

harmed by the trial court’s instruction as both the State and appellant’s statements to

the jury agreed that the evidence only supported appellant’s guilt as a party or co-

conspirator and both discussed the requisite intent appellant needed to be a party to

capital murder (5 RR at 5, 8, 9, 14, 25). See Vasquez, 389 S.W.3d at 371-72 (discussing

how both the prosecutor and Vasquez discussed party liability in their closing

arguments when holding the jury charge error harmless).            Appellant’s argument

pointed the jury to the lesser included offenses of felony murder and aggravated

robbery because appellant claimed that the evidence did not support his intent to kill

Tu (5 RR at 8, 9-10). Because the arguments of counsel reiterated to the jury that

appellant needed to intend to kill Tu to be guilty as a party to capital murder, he was

not egregiously harmed by the error, if any, in the jury charge.

      Indeed, the record, through the entire jury charge, the state of the evidence,

and the arguments of counsel, supports that even if the trial court erred in its jury

instruction on the intent needed for the jury to find appellant guilty as a party to

capital murder, appellant was not egregiously harmed by the error. However, this

Court does not need to depend upon an analysis of harm to uphold appellant’s

conviction as the trial court did not err in its charge. Therefore, this Court should

overrule appellant’s sole point of error.




                                            12
                                  CONCLUSION
      Based on the arguments stated above, the State of Texas respectfully urges the

Court to overrule appellant’s point of error and affirm his conviction.

                                                      DEVON ANDERSON
                                                      District Attorney
                                                      Harris County, Texas

                                                      /s/                   Carly Dessauer
                                                      ____________________________________________________________________________________________________________________________________________________________________________________




                                                      CARLY DESSAUER
                                                      Assistant District Attorney
                                                      Harris County, Texas
                                                       1201 Franklin, Suite 600
                                                      Houston, Texas 77002
                                                      (713) 755-5826
                                                      State Bar No. 24069083
                                                      dessauer_carly@dao.hctx.net
                                                      curry_alan@dao.hctx.net




                                          13
                      CERTIFICATE OF COMPLIANCE
      The undersigned attorney certifies that this computer-generated document has

a word count of 3,238 words, based upon the representation provided by the word

processing program that was used to create the document. TEX. R. APP. P. 9.4(i).




                                                    /s/                   Carly Dessauer
                                                    ____________________________________________________________________________________________________________________________________________________________________________________




                                                    CARLY DESSAUER
                                                    Assistant District Attorney
                                                    Harris County, Texas
                                                     1201 Franklin, Suite 600
                                                    Houston, Texas 77002
                                                    (713) 755-5826
                                                    State Bar No. 24069083




                                         14
                         CERTIFICATE OF SERVICE
      The State will serve a copy of the foregoing instrument to appellant’s attorney

though TexFile:

Charles Hinton
Attorney at Law
P.O. Box 53719
Houston, Texas 77052-3719
chashinton@sbcglobal.net
                                                    /s/                   Carly Dessauer
                                                    ____________________________________________________________________________________________________________________________________________________________________________________




                                                    CARLY DESSAUER
                                                    Assistant District Attorney
                                                    Harris County, Texas
                                                     1201 Franklin, Suite 600
                                                    Houston, Texas 77002
                                                    (713) 755-5826
                                                    State Bar No. 24069083




Date: June 25, 2015




                                         15
APPENDIX




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     I, Chris Daniel, District Clerk of Harris
     County, Texas certify that this is a true and
     correct copy of the original record filed and or
     recorded in my office, electronically or hard
     copy, as it appears on this date.
     Witness my official hand and seal of office
     this June 19, 2015


     Certified Document Number:        62067440 Total Pages: 17




     Chris Daniel, DISTRICT CLERK
     HARRIS COUNTY, TEXAS




In accordance with Texas Government Code 406.013 electronically transmitted authenticated
documents are valid. If there is a question regarding the validity of this document and or seal
please e-mail support@hcdistrictclerk.com
