I have no tools in my appellate arsenal for responding to pdr (Except the TDCAA appellate manual). Can you appellate demi-gods help me out?
Does anyone have a letter reply to pdr they can share with me?
Also, could I bother you all for a few concise formal reply briefs that I can use as models?
Reply letter form was discussed here Why Reply. A more formal reply should vary little from any other responsive brief.
I have most often used this form of prayer: "The State prays that the Court will find there is no reason for granting review under Tex. R. App. P. 66.3 or otherwise. See Hunter v. State, 954 S.W.2d 767, 769 (Tex. Crim. App. 1995) ("the Court will conduct a judicious examination into reasons asserted for granting review of the ground(s) or questions(s) thus raised vis-a-vis their importance to the jurisprudence of this State")."
Of course, be sure to discuss why an alleged error would be harmless if the court of appeals did not include a harm analysis in its opinion and point out if the PDR seeks to raise an issue not addressed by the lower court.
For one recent example: King
Thanks for the reply, Martin! The old thread is helpful, as is the Hays County reply brief.
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