THE STATE OF TEXAS
`
`VS.
`
`TORREY LEON
`
`CAUSE NO. 1618353
`
`§
`§
`§
`§
`
`§
`
`7/1/2019 2:30 PM
`Marilyn Burgess - District Clerk Harris County
`Envelope No. 34804476
`By: T Doublin
`
`IN THE 183
`
`Ifilled: 7/1/2019 2:30 PM
`JUDICIAL
`
`DISTRICT COURT OF
`
`HARRIS COUNTY, TEXAS
`
`MOTION FOR THE APPOINTMENT OF INVESTIGATOR
`
`TO THE HONORABLE JUDGE PRESIDING IN SAID COURT:
`
`COMES NOW, TORREY LEON, Defendant in the above styled and numbered cause, by and through his
`attorney of record, EILEEN BOGAR, respectfully moves the Court to appoint and provide expenses of investigation and
`expert testimony for BRANDON PLAGENS, Private Investigator, to assist in the preparation of his defense, and would
`show cause unto the Court as follows:
`
`The Defendant is charged with BURGLARY OF HABITATION , alleged to have been committed in Harris
`County, Texas.
`
`The Defendant is indigent and without funds to make his own arrangements for retaining a Private Investigator.
`
`11.
`
`I.
`
`III.
`
`Appointment of a private investigator is necessary to insure that the defendant receive his rights to effective
`assistance of counsel, cross-examination and confrontation, and compulsory process, guaranteed by the Sixth and
`Fourteenth Amendments to the United States Constitution and Article I, § 10 of the Texas Constitution; due process and
`due course of law, guaranteed by the Fourteenth Amendment to the United States Constitution and Article I, §§ l3, l9 and
`29; and, equal protection of the law, guaranteed by the Fourteenth Amendment to the United States Constitution and
`Article I, §§ 3 and 3a of the Texas Constitution.
`
`In order to conduct and complete a thorough investigation, it is imperative that all law enforcement agencies
`within The State of Texas permit and extend the same courtesy and access afforded defense attorneys, to BRANDON
`PLAGENS for interviewing of the Defendant and all witnesses that may be held in law enforcement custody, and that said
`investigator be afforded an unprejudiced opportunity to interView all witnesses know to the State, and the Defendant.
`
`IV.
`
`WHEREFORE, premises considered, the Defendant prays that the Court will grant this Motion for the
`Appointment of Investigator, and appoint BRANDON PLAGENS, Private Investigator, to assist him in the preparation of
`his defense and heretofore stated reasons that the Court order the Treasurer of Harris County, Texas to pay the cost of
`such investigative serVices directly to BRANDON PLAGENS.
`
`V.
`
`Respectfully submitted:
`
`W E
`
`ILEEN BOGAR
`
`TBN 24033824
`
`6309 Skyline, Suite D
`Houston, Texas 77057
`
`Tel. (713) 858-0700
`ATTORNEY FOR DEFENDANT
`
`

`

`7/1/2019 2:30 PM
`Marilyn Burgess - District Clerk Harris County
`Envelope No. 34804476
`By: T Doublin
`Filed: 7/1/2019 2:30 PM
`
`CAUSE NO. 1618353
`
`THE STATE OF TEXAS
`
`VS.
`
`TORREY LEON
`
`§
`§
`§
`§
`
`§
`
`IN THE 183“” JUDICIAL
`
`DISTRICT COURT OF
`
`HARRIS COUNTY, TEXAS
`
`ORDER FOR THE APPOINTMENT OF INVESTIGATOR
`
`On this day came on to be heard the Defendant’s Motion for the Appointment of
`Investigator in order that he may aSSiSt the defense in the above Styled and numbered cause pending
`before the court.
`
`The Court, after having read the pleadings, iS of the opinion that said Motion Should be in
`all things GRANTED.
`
`iS therefore ORDERED that BRANDON PLAGENS, Private Investigator, be
`It
`appointed by the Court aS the investigator for the Defendant.
`
`It iS also ORDERED that all law enforcement agencies within The State of Texas permit
`and extend the same courtesy and acceSS afforded defense attorneys, to BRANDON PLAGENS, Private
`Investigator, for purposes of conducting interviews of the Defendant and all witnesses that may be held in
`law enforcement custody. Specifically, it is further ordered that the Harris County Sheriffs Office allow
`acceSS to TORREY LEON, with a SPN 02859740 with a Date of Birth of 09/08/1997, and that the
`
`Harris County Sheriff” s Office allow the private investigator, BRANDON PLAGENS, PI LIC# A-
`07292901, named herein to enter the Harris County Jail with a laptop computer, printer and an audio
`recording device when visiting the defendant.
`
`iS further ORDERED that BRANDON PLAGENS, Private Investigator, after
`It
`conclusion of hiS investigation and tendering hiS Statement, Shall be directly monetarily compensated by
`the Treasurer of Harris County, Texas for hiS services.
`
`Funding for Investigator iS granted in the amount of
`
`$ 600.00
`
`Signed and entered this
`
`day of
`
`, 2019.
`
`HONORABLE CHUCK SILVERMAN
`
`183;RD Judicial District Court
`
`of Harris County, Texas
`
`