November 24, 2015Grand Jurors of Dallas County, Texas
Frank Crowley Courts Building
133 N. Riverfront Blvd # *****
Dallas, Texas 75207Re: The State of Texas vs. Matthew
Cause Number (cause number)Allegation of Attempted Sexual AssaultDear Members Of The Dallas County Grand Jury
I represent Mr. ______ in connection with the above referenced matter.
Having reviewed and investigated carefully all the facts and circumstances surrounding this matter, I am respectfully ***** ***** Mr. _____________ case be “no billed” by the Dallas County Grand Jury. I would offer the following information in support of this position.BACKGROUND
(set out the background and family situation of the _____________ in a light favorable to the _____________)
PRIOR CRIMINAL LAW MATTERS
(set out the _____________’s lack of criminal history or set out criminal history in manner as favorable to _____________ as possible)CHRONOLOGY OF ALLEGED OFFENSE DATE
(set out chronology of offense date in manner favorable to _____________ keeping in mind the facts that the grand jury will hear from the prosecutor)ARREST
(set out chronology of the _____________’s arrest in manner favorable to _____________ keeping in mind the facts that the grand jury will hear from the prosecutor)
(set out the applicable law in a light favorable to _____________)EXPLANATION OF PHYSICAL EVIDENCE AGAINST _____________
(explain the physical evidence in a manner favorable to _____________ keeping in mind the facts that the grand jury will hear from the prosecutor)(Title
this section according to content about favorable aspects of _____________’s life)
(set out favorable factors such as charitable or community activities, awards, certifications, etc.)CORRECTIVE MEASURES
(here recite the steps _____________ has taken to correct the situation that resulted in his arrest)CONCLUSION
In the event that you desire any of the witnesses in support of Mr. _____________ to be present at the Grand Jury to offer testimony
under oath, I have agreed to make them available.. I make this offer because there is simply nothing to withhold in connection with this case. Mr. _____________’s actions and the events of (date of alleged offense) are well-documented.
I would respectfully ***** ***** the Grand Jury no-bill Mr. _____________.
Thank you for your courtesy in connection with review of this matter.Sincerely,
Paul Lawyer, Attorney and Counselor at Law