On June 15, 2023 a
Answer
was filed
involving a dispute between
Le Roy, Andrew John,
and
The State Of Texas,
for Occupational Drivers License
in the District Court of Fort Bend County.
Preview
CAUSE NO. 23-CCV-073021
§ COUNTY COURT AT LAW
EX PARTE §
§ NO. TWO (2) OF
OHN LEROY
FORT BEND COUNTY, TEXAS
S RESPONSE TO PETITIONER’S PETITION
‘OR AN OCCUPATIONAL DRIVER’S LICENSE
TO THE HONOR B EJUD E OF SAID COURT:
COM# NOW THE SP. IE OF TEXAS, by and through its undersigned Assistant District
Attorney and submits the £0 g Response to Petitioner’s Petition for an Occupational License.
After review of the etition, supporti ac ents, and the Criminal History of the Petitioner:
EX] The State of Texas i (OPPOSED to the Petition; or,
(21 The State of Texas is\O POSED to t] he Pe on
In support of this position, the State would ie 1a1l0
KX] Petitioner has not submitted a certified copy 2 QP Driyiit; Record; and/or,
(1 Petitioner does not have a Texas Driv: ense Numb and/or,
LJ Petitioner has not submitted evidence ofan SR- owing pre-paid insurance for a coverage
period of six-months; and/or,
(O Petitioner has been convicted of a DWI or other Alcé elated O nse within the previous
five years; and/or,
[1 Petitioner has a Commercial Driver’s License (CD d/o
Petitioner may pose a danger to the community and public safet Vit ced by: PENDING
SY
DWI (FBC).
Additionally, The State would further advise the Court of the following:
(1 Petitioner’s request exceeds or appears to exceed twelve hours in any 2: -houf period b ed
on their occupation or stated hour requests; and/or,
C1 Petitioner’s past behavior and criminal history suggest that an interlock req ment would
be appropriate as a condition of the Occupational License; and/or,
(1) Petitioner’s D.L. has been expired for more than two years and retesting is required; and/or,
~ ~—
Petitioner is requesting a contemporaneous driving log; and/or,
(1 Petitioner ould have a geographical limitation to Fort Bend County and its neighboring
; and/or,
ther:
WHEREFO Ey the requests the Court to support its aforementioned stances and
concerns In if ing and Orde ding the Petitioner’s Request for an Occupational License.
Additionally, req hat this filed Response is included in the official record
on this matter and thatthe Codrt ve tate’s personal appearance at any subsequent hearing
regarding this matter, or alt¢rndtively Orderyth State to appear at any subsequent hearing, if State’s
personal appearance is deemednecessar
GIF ux SUBMITTED,
Cy)
th DdK\GA
lia ON
Q
BOT: 24128527
FILED FOR RECORD A torey
NO___ TIME /0: 6° aap SSISI
‘ort Bend County D trict Attorney’s Office
JUN 21. 2023
.
County Clerk Fart Bend Co. Texas
YY
V7/ (25
UPDATED 15 OCT 2021
_ ee
Document Filed Date
June 21, 2023
Case Filing Date
June 15, 2023
Category
Occupational Drivers License
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Preview
CAUSE NO. 23-CCV-073021 § COUNTY COURT AT LAW EX PARTE § § NO. TWO (2) OF OHN LEROY FORT BEND COUNTY, TEXAS S RESPONSE TO PETITIONER’S PETITION ‘OR AN OCCUPATIONAL DRIVER’S LICENSE TO THE HONOR B EJUD E OF SAID COURT: COM# NOW THE SP. IE OF TEXAS, by and through its undersigned Assistant District Attorney and submits the £0 g Response to Petitioner’s Petition for an Occupational License. After review of the etition, supporti ac ents, and the Criminal History of the Petitioner: EX] The State of Texas i (OPPOSED to the Petition; or, (21 The State of Texas is\O POSED to t] he Pe on In support of this position, the State would ie 1a1l0 KX] Petitioner has not submitted a certified copy 2 QP Driyiit; Record; and/or, (1 Petitioner does not have a Texas Driv: ense Numb and/or, LJ Petitioner has not submitted evidence ofan SR- owing pre-paid insurance for a coverage period of six-months; and/or, (O Petitioner has been convicted of a DWI or other Alcé elated O nse within the previous five years; and/or, [1 Petitioner has a Commercial Driver’s License (CD d/o Petitioner may pose a danger to the community and public safet Vit ced by: PENDING SY DWI (FBC). Additionally, The State would further advise the Court of the following: (1 Petitioner’s request exceeds or appears to exceed twelve hours in any 2: -houf period b ed on their occupation or stated hour requests; and/or, C1 Petitioner’s past behavior and criminal history suggest that an interlock req ment would be appropriate as a condition of the Occupational License; and/or, (1) Petitioner’s D.L. has been expired for more than two years and retesting is required; and/or, ~ ~— Petitioner is requesting a contemporaneous driving log; and/or, (1 Petitioner ould have a geographical limitation to Fort Bend County and its neighboring ; and/or, ther: WHEREFO Ey the requests the Court to support its aforementioned stances and concerns In if ing and Orde ding the Petitioner’s Request for an Occupational License. Additionally, req hat this filed Response is included in the official record on this matter and thatthe Codrt ve tate’s personal appearance at any subsequent hearing regarding this matter, or alt¢rndtively Orderyth State to appear at any subsequent hearing, if State’s personal appearance is deemednecessar GIF ux SUBMITTED, Cy) th DdK\GA lia ON Q BOT: 24128527 FILED FOR RECORD A torey NO___ TIME /0: 6° aap SSISI ‘ort Bend County D trict Attorney’s Office JUN 21. 2023 . County Clerk Fart Bend Co. Texas YY V7/ (25 UPDATED 15 OCT 2021 _ ee