STATE OF TEXAS 57~~ DISTRICT COURT - - -

::JU..LI ~~ L. 1Su..iLT TARRANT COUNTY, TEXAS

CAPITAL DEFENSE CLAIM FOR FEE PAYMENT/EXPENSES

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For Judge s Use Only

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preparation, etc.)
APPELLATE WORK
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EXPENSES
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PURSUANT TO ARTICLE 26.05 TEX. CODE CRIM. PROC. 1, THE UNDERSIGNED JUDGE,
TO PAY FROM THE GENERAL FUND OF SAID
L THE TOTAL AMOUNT SHOWN ABOVE FOR
ICES AND/OR EXPENSES IN THE ABOVE-

s11- t'J1srcouRT
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Effective 12/14/01
DC-692 GPC-1901
 LAW OFFICES OF
MOOR£ &. CUMMINGS
A Law Firm of Independent Attorneys
4210 West Vickery Boulevard
Fort Worth, Texas 76107
(817) 338-4800 Office
(817) 989-2442 Fax
Larry M. Moore Fred Cummings, OfCounsel
Board Certified - Criminal Law Board Certified - Criminal Law
Texas Board ofLegal Specialization Texas Board of Legal Specialization
Board Certified - Criminal Trial Advocate
Kimberly J. Moore, Legal Assistant National Board of Trial Advocacy
Board Certified - Criminal Law
Texas Board of Legal Specialization April 81h, 2003

Hon. Scott Wisch

Judge, 372nd Jud. District Court
401 West Belknap Street
Fort Worth, Texas 76196

RE: State of Texas v. Julian C. Burt

Cause No. 0714820D - Capital Murder
Cause No. 0714825D - Capital Murder
Cause No. 0714828D- Murder
Cause No. 0879680V- Assault on Pub.lic Servant
(Bee Co. Indictment No. B-01-M014-1-PR-B, Transferred on Change of Venue)
372'd Judicial District Court, Tarrant County, Texas

STAT£M£NT
For Legal Services Rendered:

Date Activity Time

10-5-01 Receipt/review telephone message from Court Coordinator re: .10 hr.
possible appointment; need to stop by to see J. Wisch on Monday,
10-8-01.

10-8-01 Conference with J. Wisch re: possible appointment to succeed .40-hr.

Ward Casey as lead counsel; Defendant to be brought down on
Thursday, 10-11-01 at 1:30 p.m., for appointment; receipt/review copy of
....
Defendant's case list from Court Coordinator.

10-9-01 Receipt/review telephone message from Court Coordinator, .10 hr.

Defendant to be brought down Wednesday, 10-10-01, at 10:00 a.m.

10-10-01 APPOINTED in open court by J. Wisch on Court's Motion to succeed 1.00 hr.
Ward Casey; conference with Defendant; conference with Court;

Page 1 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt 001-564041-41245
 received copy of Order of Appointment from Court Clerk.

10-25-01 Conference with prosecutor (G. Miller), received copy of State's 2.00 hr.
offense reports; initial cursory review of State's offense reports.

10-26-01 Conference with J. Kit Cooke re: scheduling; conference with J. Wisch .50 hr.
re: scheduling.

11-12-01 Telephone call to Ward Casey's office re: obtaining case file. .20 hr.

11-14-01 Receipt/review telephone message from Defendant's mother, return .50 hr.
telephone call to Defendant's mother; telephone conference with Ward
Casey's office, to pick up Ward Casey's file on 11-15 or 11-16-01.

11-16-01 Telephone conference with Ward Casey's office; travel to Ward Casey's .75 hr.
office to pick up Ward Casey's file, file not available.

11-19-01 Telephone conference with Ward Casey's office re: case file. .20 hr.

12-17-01 Telephone conference with Ward Casey's office re: picking up case file. .25 hr.

12-19-01 Telephone conference with Ward Casey's office re: picking up case file; 1.75 hr.
travel to Ward Casey's office, picked up case file; office conference
with Defendant's parents.

12-19-01 Initial review of Ward Casey's file; part of the file involving the federal 3.00 hr.
to writ application was missing.
1-3-02

1-3-02 Conference with prosecutor (G. Miller), plea bargain offer made; 2.50 hr.
telephone call to Ward Casey's Office re: missing part of case file;
office conference with co-counsel, Payton Hunt, re: status, division
of work, etc.

1-14-02 Receipt/review letter from prosecutor (G. Miller) detailing case status .25 hr."'
and plea bargain offer being made to Defendant.

1-15-02 Receipt/review telephone message from co-counsel, Payton Hunt. .1 0 hr.

1-17-02 Receipt/review trial notebook prepared by Payton Hunt; receipt/review 2.00 hr.
of "missing" part of Ward Casey's file regarding federal writ application,
received from Payton Hunt; file review.

Page 2 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
1-19-02 Receipt/review telephone message from prosecutor (G. Miller); telephone 1.00 hr.
conference with prosecutor (G. Miller); sent copy of prosecutor's letter
with plea bargain offer to co-counsel; Payton Hunt; file review.

1-25-02 Conference with Court Coordinator re: status and scheduling of trial. .25 hr.

2-4-02 Telephone conference with prosecutor (G. Miller) re: plea offer, plea .40 hr.
offer deadline and scheduling of trial.

2-5-02 Telephone conference with Defendant in Tarrant County Jail re: plea .25 hr.
51
offer and deadline for accepting offer of August 1 , 2002; trial status; etc.

3-11-02 Receipt/review faxed letter from co-counsel, Payton Hunt, together with .25 hr.
obituary notice for co-defendant Malcolm Griffin.

3-18-02 Receipt/review telephone message from prosecutor (G. Miller); telephone .50 hr.
conference with prosecutor (G. Miller) re: pending Bee Co. assault on
public servant offense; file review.

Receipt/review letter from prosecutor (G. Miller) together with offense 2.00 hr.
3-20-02
reports and witness statements re: Bee Co. case; file review.

Conference with Court (J. Wisch) re: trial schedule. .40 hr.
5-2-02

Review of offense reports, witness statements, and case file; legal 10.00 hr.
7-1-02
to research re: applicable parole statute; legal research re: potential
7-2-02 defenses; telephone calls and investigation re: State's witnesses;
began work on Defendant's pretrial motions.

Conference with Defendant in Tarrant County Jail re: plea offer; offer 1.50 hr.
7-3-02
deadline; and trial schedule.

Telephone conference with prosecutor (G. Miller) re: status; telephone .75 hr.
7-3-02
conference with Defendant's parents re: possible jury room conference
with Defendant re: plea offer and deadline for acceptance of offer; file
review.

7-12-02 Went by 372nd Court, J. Wisch out for the week; conference with Court 4.00 hr.
Coordinator re: possible jury room conference with Defendant and
his parents re: plea offer, conference scheduled for Tuesday, July 16th,
2002 at 8:30a.m.; conference with Court bailiffs re: jury room conference

Page 3 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
 on July 16th; telephone call to co-counsel, Payton Hunt, re: jury room
conference; telephone conference with Defendant's father re: conference;
review of writ appeal file; telephone calls to Court Clerk's Office for United
States Court of Appeals for the Fifth Circuit re: status of writ appeal; telephone
call to investigator (B. Cummings); file review and preparation for jury room
conference.

7-15-02 Telephone conference with prosecutor (G. Miller) re: bench warrant from 4.00 hr.
Bee County issued for Defendant, and information re: alleged extraneous
offenses; receipt/review telephone message from Court Coordinator;
telephone call to investigator (B. Cummings); telephone conference with
Investigator (B. Cummings) re: witness interviews; conference with prosecutor
(G. Miller); file review and preparation for conference with Defendant and his
parents.

7-16-02 Conference with Defendant and his parents in 372nd District Court jury 4.00 hr.
room; conference with Court; conference with prosecutor (G. Miller);
conference with Defendant's parents.

7-24-02 Telephone conference with attorney Kyle Allen, Defendant's Staff 1.50 hr.
Counsel in Bee County assault on public servant case, plea offer in
Bee County case is Section 12.45 "plea in bar"; telephone conference
with J. Wisch re: Bee County bench warrant having been issued, Tarrant
County Sheriff to hold Defendant here pending resolution of plea negotiations;
telephone conference with prosecutor (G. Miller) re: Defendant's being held
here pending decision on plea bargain offer.

7-31-02 Receipt/review telephone message from prosecutor (G. Miller) re: plea .1 0 hr.
bargain offer deadline of 8-1-02, question re: status.

8-1-02 Conference with prosecutor (G. Miller), plea deadline to be extended in .40 hr.
order for me to have further discussions with Defendant and his family;
discussed trial scheduling in case plea bargain offer is rejected.

8-2-02 Conference with investigator (B. Cummings) re: witness interviews; .75 hr. . .
receipt/review telephone message from investigator (B. Cummings)
re: interviews; file review of witness statements.

8-3-02 Conference with Defendant in Tarrant County Jail re: plea offer, trial 2.50 hr.
schedule, etc; file review and outlining of tasks to be accomplished.

8-4-02 Telephone call to Defendant's parents re: status of plea bargaining. .20 hr.

Page 4 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
8-7-02 Receipt/review telephone message from Defendant's father. .1 0 hr.

8-10-02 Telephone call to Defendant's parents; telephone conference with .50 hr.
Defendant's parents re: plea offer, trial status, etc.

8-16-02 Conference with Defendant in Tarrant County Jail re: plea bargain offer, 1.50 hr.
trial status, etc.

8-21-02 Receipt/review telephone message from prosecutor (G. Miller); .60 hr.
conference with prosecutor re: plea offer, he's to send letter setting a
new plea deadline.

8-23-02 Receipt/review faxed letter from prosecutor (G. Miller), plea bargain offer .20 hr.
deadline extended, offer expires on 9-12-02.

8-23-02 Receipt/review hard copy of letter from prosecutor (G. Miller) extending .10 hr.
plea bargain ·offer deadline to 9-12-02.

8-26-02 Preparation and drafting of letter to Defendant, copies to investigator, .50 hr.
co-counsel and Defendant's parents re: new plea bargain deadline,
Bee County case, trial status, etc.

8-29-02 Receipt/review copy of letter sent to co-counsel, returned by Postal .10 hr.
Service as forwarding address expired.

9-10-02 Conference with Defendant in Tarrant County Jail. 1.50 hr.

9-10-02 Legal research re: parole applicability for "stacked" sentences and 2.00 hr.
concurrent sentences; legal research re: mandatory "stacking," and
"stacking" orders; research re: paroles granted on capital life sentences
over last few years.

9-12-02 Conference with Defendant in Tarrant County Jail, State's plea bargain 1.25 hr.,..
offer refused.

9-13-02 Telephone conference with prosecutor (G. Miller) re: plea bargain offer 2.00 hr.
being refused by Defendant' conference with Court (J. Cooke) re: scheduling
of trial and plea bargain refusal; conference with Court Coordinator re:
scheduling of trial; file review and outlining of tasks to be 'completed for trial.

10-30-02 Telephone conference with Court (J. Wisch) re: trial scheduling and Bee .25 hr.

Page 5 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
 County bench warrant.

11-8-02 Receipt/review telephone message from Court Coordinator, a scheduling .20 hr.
conference has been set for 11-14-02.

11-11-02 Telephone call to Defendant's parents re: scheduling conference; 1.00 hr.
telephone call to investigator; telephone call to co-counsel; telephone
call to prosecutor (G. Miller).

11-12-02 Receipt/review setting notice (11-14-02 pretrial scheduling conference). .1 0 hr.

11-13-02 Telephone conference with Defendant's parents re: scheduling .25 hr.
conference.

PRETRIAL CONFERENCE- J. Kit Cooke presiding; discussion of plea 4.00 hr.

bargain offer; trial schedule set; conferences with Court (J. Cooke), J.
Wisch, prosecutor (G. Miller) co-counsel (Payton Hunt), investigator
(B. Cummings), Defendant, Defendant's parents, and Court Coordinator.

11-14-02 Conference with prosecutor (G. Miller) re: possible new plea offer. .40 hr.

11-18-02 Conference with Court Coordinator re: possible new plea offer and Bee .30 hr.
County bench warrant.

11-25-02 Telephone conference with prosecutor (G. Miller) re: new plea offer. .25 hr.

12-4-02 Receipt/review letter from prosecutor (G. Miller) with "draft" copies of 2.50 hr.
plea agreements and plea forms; telephone conference with Defendant's
mother re: status; telephone call to attorney Kyle Allen, Staff Attorney
representing Defendant in Bee County case; file review and work on
pretrial motions.

12-10-02 Telephone conference with attorney Kyle Allen, he is no longer with Staff 2.00 hr.
Counsel's Office and does not know status of plea bargain offer in Bee
County case; telephone conference with Staff Counsel's Office, Scott
Pawgan is Defendant's new attorney; telephone call to attorney Scott Pawgan;
telephone calls to Defendant's mother; receipt/review telephone message
from attorney Scott Pawgan; telephone conference with attorney Scott
Pawgan re: status of Bee County case and plea offer; file review and work
re: pretrial motions to be filed, investigation to be done.

12-12-02 Telephone conference with attorney Scott Pawgan. .40 hr.

Page 6 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
12-13-02 Conference with prosecutor (G. Miller) re: status and plea bargain offer. .40 hr.

12-17-02 Telephone conference with Court Coordinator re: trial scheduling and .20 hr.
possible plea.

12-18-02 Conference with Defendant in Tarrant County Jail; conference with 2.25 hr.
Court (J. Wisch) re: Bee County case and plea bargain offer.

12-19-02 Conference with prosecutor (G. Miller) re: new plea offer; telephone 1.50 hr.
calls to Defendant's parents; telephone call to co-counsel (Payton Hunt);
file review.

12-20-02 Telephone conference with prosecutor (G. Miller) re: new plea bargain 1.75 hr.
offer; receipt/review telephone message from attorney Scott Pawgan;
telephone call to attorney Scott Pawgan; telephone conference with
investigator (8. Cummings); copied witness statements for investigator;
telephone call to investigator; receipt/review telephone message from
attorney Scott Pawgan; file review and trial preparation.

12-23-02 Conference with attorney Scott Pawgan re: Bee County assault on 3.00 hr.
public servant case, received copies of witness statements and
investigator's reports in Bee County case; review of reports and
statements; telephone calls with prison units re: scheduling of investigator's
interviews with inmate witnesses.

12-27-02 Receipt/review telephone messages from investigator (B. Cummings); 1.50 hr.
receipt/review information faxed from prison units; telephone call to
investigator (B. Cummings), receipt/review telephone message from attorney
Scott Pawgan; telephone call to attorney Scott Pawgan; telephone conference
with attorney Scott Pawgan; file review and trial preparation.

12-30-02 Completed forms for investigator's interviews of prison inmate 1.25 hr.
witnesses; faxed completed forms to prison units; telephone call to
investigator ;receipt/review telephone message from investigator; file review.

1-6-03 Receipt/review telephone message from investigator (B. Cummings); 1.25 hr.
telephone conference with investigator re: witness interviews of prison
inmates; file review and trial preparation.

1-7-03 Telephone conference with co-counsel re: status and his obtaining copies .40 hr.
of co-defendants' plea agreements and transcripts of pleas.

Page 7 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
1-9-03 Receipt/review letter from Court (J. Wisch) with trial scheduling order. .20 hr.

1-21-03 Receipt/review telephone message from prosecutor (G. Miller); 1.50 hr.
telephone calls to and from prosecutor; telephone conference with
prosecutor, new plea bargain offer made; receipt of information obtained
by co-counsel (Payton Hunt) re: co-defendants' plea agreements and
transcripts of sentencing hearings; review of co-defendant's plea agreements.

1-22-03 Conference with Defendant in Tarrant County Jail re: new plea offer and 1.50 hr.
trial schedule.

1-24-03 Review of co-defendants' plea agreements, transcripts of co-defendants' 2.50 hr.

pleas, and witness statements; telephone calls and investigation re:
co-defendant witnesses and impeachment information.

1-28-03 Telephone call to prosecutor (G. Miller); file review. .50 hr.

1-29-03 Receipt/review telephone message from prosecutor (G. Miller); .50 hr.
telephone conference with prosecutor.

2-4-03 Telephone conference with attorney Scott Pawgan re: transfer of Bee 1.75 hr.
County case on change of venue; office conference with Defendant's
Mother; file review and trial preparation.

2-5-03 Telephone conference with prosecutor (G. Miller); telephone call to .75 hr.
attorney Scott Pawgan; file review and trial preparation.

2-6-03 Receipt/review faxed letter from prosecutor (G. Miller) together with 2.75 hr.
Rule 404(b) and Article 37.07 notice of extraneous offenses; conference.
with prosecutor, received hard copy of letter and extraneous offense notice,
deadline established for new plea bargain offer of 3-1-03; telephone call to
attorney Scott Pawgan; telephone conference with attorney Scott Pawgan;
receipt/review telephone message from Court (J. Wisch); telephone con-
ference with Court Coordinator, set Court conference for 2-7 -03; conference
with co-counsel (Payton Hunt), set up conference with Defendant and
co-counsel for 2-7-03; review of extraneous offense notice; file review and
trial preparation.

2-7-03 Conference with Defendant and co-counsel (Payton Hunt) in Tarrant 3.50 hr.
County Jail; conference with co-counsel, set office conference for
2-1 0-03; conference with Court (J. Wisch) re: scheduling; telephone

Page 8 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
 conference with attorney Scott Pawgan, Bee County case not being
transferred; telephone call to investigator, set office conference for
2-1 0-03; file review and outlining of witnesses to be interviewed, and
tasks to be accomplished in preparation for trial.

2-10-03 Receipt/review telephone messages from co-counsel (Payton Hunt) and 2.50 hr.
investigator (B. Cummings); file review; office conference with co-counsel
and investigator re: witnesses to be interviewed and trial preparations to
be completed.

2-18-03 Receipt/review telephone message from Defendant in Tarrant County 3.25 hr.
Jail; telephone conference with Defendant in Tarrant County Jail;
telephone call to prosecutor (G. Miller); telephone conference with
Investigator (B. Cummings); re: interviews of witnesses; receipt/review
telephone message from investigator; telephone call to attorney Scott
Pawgan; conference with Court (J. Wisch), Court has signed Change of
Venue Order transferring Bee County case to 372nd Jud. District Court; file
review and trial preparation.

2-19-02 Telephone call to prosecutor (G. Miller); receipt/review telephone 1.75 hr.
message from prosecutor; telephone conference with prosecutor re:
plea bargain offer and transfer of Bee County case; letter to Defendant
with copy of extraneous offense notice, copies to Defendant's parents,
co-counsel and investigator; telephone conference with Defendant's mother
re: letter and plea offer.

2-20-03 Receipt/review telephone message from attorney Scott Pawgan; .20 hr.
telephone call to Scott Pawgan.

2-26-03 Receipt/review telephone message from attorney Scott Pawgan; 1.00 hr.
telephone calls to and from attorney Scott Pawgan; telephone conference
with attorney Scott Pawgan; receipt/review telephone message from
prosecutor (G. Miller); telephone call to prosecutor.
,.
2-27-03 Telephone calls to and from prosecutor (G. Miller). .40 hr.

2-28-03 Receipt/review telephone message from prosecutor (G. Miller); 4.00 hr.
went by to see prosecutor at D.A.'s Office, not there; telephone
conference with prosecutor re: status, plea bargain offer extended for
a few days; telephone conference with Court (J. Wisch) re: jury room
conference with Defendant and his parents, we can meet Monday,
3-3-03; telephone conference with Defendant's mother re: possible jury room

Page 9 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
 conference, plea offer, etc.; telephone conference with prosecutor; telephone
conference with attorney Scott Pawgan; telephone call to co-counsel;
receipt/review message from co-counsel; telephone call to investigator
(B. Cummings) re: conference; file review and preparation for conference.

3-3-03 Telephone conference with Defendant in Tarrant County Jail; telephone .40 hr.
call to co-counsel re: jury room conference set this afternoon.

3-3-03 Conference with Defendant, Defendant's parents, co-counsel (Payton 2.75 hr.
Hunt) and investigator (B. Cummings) in 372nd Dist. Court jury room;
conferences with Court (J. Wisch), prosecutor (G. Miller), Court bailiffs,
and Defendant's parents.

3-4-03 Telephone calls to and from prosecutor (G. Miller); telephone conference 4.00 hr.
with prosecutor re: plea offer in Bee County Case; telephone conference
with Defendant's parents; conference with Defendant in Tarrant County
Jail re: plea offers; conference with prosecutor; conferences with Court
Coordinator, set plea proceeding for Monday, 3-10-03; conference with
Investigator; telephone call to attorney Scott Pawgan; telephone con-
ference with attorney Scott Pawgan; telephone call to co-counsel Payton
Hunt; file review.

3-9-03 Telephone conference with co-counsel, Payton Hunt, re: plea setting. .20 hr.

3-10-03 Receipt/review draft copies of plea agreements, written admonishments 1.00 hr.
and plea paperwork from prosecutor (G. Miller); file review and review of
applicable statutes.

3-10-03 PLEA SETTING- conferences with Defendant, co-counsel, (Payton 2.50 hr.
Hunt), attorney Scott Pawgan, Court (J. Wisch), and Defendant's parents;
Defendant executes plea paperwork; Defendant enters pleas of "guilty"
in all cases; Defendant sentenced by Court (J. Wisch) to Life in three
cases; Defendant to three (3) years' incarceration "stacked" on prior murder
conviction in Bee County case. ....

3-10-03 Conferences with Court, Defendant, Defendant's parents and 1.50 hr.
Defendant's daughter in courtroom after Defendant's plea. entered
and accepted.

TOTAL HOURS: 126.75 HRS.

Page 10 of 11. Larry M. Moore, Attorney

Defendant, Julian C. Burt
 TOTAL COURT APPEARANCES: 3 Appearances
10-10-01- Appointment
11-14-02- Pretrial Conference
3-10-03 - Plea Setting

TOTAL IN-COURT HOURS: 7.50 hrs.

TOTAL OUT-OF-COURT HOURS: 119.25 hrs.

TOTAL HOURS: 126.75 HRS.

Page 11 of 11, Larry M. Moore, Attorney

Defendant, Julian C. Burt
 LAW OFFICES OF
MOOR£ & CUMMIN6.S
A Law Firm of Independent Attorneys
4210 West Vickery Boulevard
Fort Worth, Texas 76107
(817) 338-4800 Office
(817) 989-2442 Fax
Larry M. Moore Fred Cummings, OfCounsel
Board Certified - Criminal Law Board Certified - Criminal Law
Texas Board of Legal Specialization Texas Board of Legal Specialization
Board Certified - Criminal Trial Advocate
Kimberly J. Moore, Legal Assistant National Board of Trial Advocacy
Board Certified - Criminal Law
Texas Board of Legal Specialization
April ath, 2003

Hon. Scott Wisch

Judge, 372"d Jud. District Court
401 West Belknap Street
Fort Worth, Texas 76196

RE: State of Texas v. Julian C. Burt

Cause No. 07148200 - Capital Murder (Multiple Victims)
Cause No. 07148250- Capital Murder (Multiple Victims)
Cause No. 07148280- Murder
Cause No. 0879680V- Assault on Public Servant
(Bee Co. Indictment No. B-01-M014-1-PR-B, Transferred on Change of Venue)
37~d Judicial District Court, Tarrant County, Texas

Dear Judge Wisch:

As you will recall, you ori~inally appointed me to represent the Defendant in the above-
referenced cases on October 1ot , 2001, when Ward Casey was suddenly and regrettably taken
from us. At that point, the cases had been pending for some time, so it took a good deal of effort
and time for me to get become familiar with these matters. As you know, the cases were
eventually disposed by the entry of agreed pleas, entered before you on March 1oth, 2003, wherein
the Defendant was sentenced to three (3) concurrent life sentences in the capital murder and
murder cases, and to three (3) years' incarceration "stacked" upon the Defendant's previous
murder conviction in the assault on public servant case transferred from Bee County to your Cqurt.

Due to the serious nature of these offenses, and the fact that it appeared that these cases
would require a jury trial in order to be disposed, I spent a considerable amount of time in my
representation of this Defendant prior to the entry of his agreed pleas. As you will recall, the
Defendant's death penalty trial was scheduled to begin in May, when an acceptable plea bargain
agreement was finally reached in March. Due to the amount of time that I expended in the
representation of this Defendant, I have prepared an itemized statement for your review in the
authorization of attorney's fees in this matter.

My co-counsel in these cases, Payton Hunt, is submitting his bill contemporaneously with
mine. It is my understanding that our investigator, Bruce Cummings, has already submitted his bill

001-564M ··t-412 45
under a separate cover. These should constitute all of the statements that will be submitted to the
Court in these matters.

I wish to advise the Court that I was extremely pleased with the assistance that my co-
counsel, Payton Hunt, and our investigator, Bruce Cummings, provided to me in these matters.
Due to the unusual circumstances surrounding these cases, and the fact that I was abruptly
inserted as lead counsel several years after the cases were indicted, there were some additional
problems in these cases which don't normally occur. Payton Hunt did a tremendous job of
obtaining materials and organizing files after Ward Casey's untimely death. This enabled me to
"get up to speed" much more quickly than would otherwise have been possible. Bruce Cummings
did an excellent job of finding witnesses whom we had questions about, and interviewing the
prospective State's witnesses, so that Mr. Burt could ultimately make an informed decision in
deciding whether or not to accept the final plea bargain offer which was made to him. I greatly·
appreciated their efforts throughout these cases and I enjoyed working with them in these matters.

I sincerely appreciate the opportunity that you have me to undertake the defense of these
difficult and challenging cases. Please advise me if you have any questions in regard to my
representation of this Defendant, or the statement which I have submitted for your review. As
always, it has been a pleasure to appear in your Court, and to work with your staff.

LMM/km
Enclosure