7/8/2019 11:14 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS ‘SR DEPUTY No. F18-00737 STATE OF TEXAS. SR In the 204th District Court Dallas County AMBER RENEE GUYGER Defendant’s Motion to Transfer the Venue from Dallas County Toby Shook 2001 Bryan Street Suite 1905 Dallas, TX 75201 Office: 214-850-9229 Fax: 214-880-0409 tobyshook@tobyshooklaw.com Texas Bar No. 18293250 Attomey for Defendant Robert L. Rogers 12001 N. Central Exp. Suite 650 Dallas, TX 75243 Phone: 214-965-0090 Fax: 214-965-0097 rlrogerslaw@me.com Texas Bar No. 00797342 Attorney for Defendant Michael Mowla P.O. Box 868 Cedar Hill, TX 75106 Phone: 972-795-2401 Fax: 972-692-6636 michael@mowl y.com Texas Bar No. 24048680 Attomey for DefendantL Table of Contents I, Table of Contents.. Il. Table of Authorities. IIL Table of Appendices. IV. Introduction... V. Facts VIL Argument ... 1. Constitutional standards under the Sixth Amendment and Tex. Const. Art. I, § 10 of the right to a fair trial by 2. General requirements to show that a change of venue is necessary. 3. Statutory requirements under Tex. Code Crim. Proc. Art. 31.03 for a change of venue. 4. The Henley factors for a change of venue... 5. The publicity surrounding this case has been perva: prejudicial, and inflammatory 6. Government interference occurred in this case that violated Defendant's deeply rooted and fundamental ixth Amendment, so rights under the right to a fair trial under the § Defendant's Substantive Due Proces: Fourteenth Amendment were violated. 7. Other government officials injected themselves into this case, which in turn led to an opportunist to take advantage of the tragedy of Mr. Jean’s death, which further violated Defendant’s rights under the Sixth and Fourteenth Amendments...Vil. VIL. The hysteria and false narratives have been pervasive and wide-spread, which have added significantly to the existing false-narratives and hysteria that pervades in Dallas County, making a fair trial here impossibl No amount of voir dire or other remedial action by the trial court can erase or mitigate the pervasive, prejudicial, and inflammatory publicity in this case and thus would be inadequate to protect Defendant's constitutional and statutory rights to an impartial jury Defendant has met the statutory requirements for a change of venue under Tex. Code Crim. Proc. Art. 31.03. Defendant has met the Henley factors for a change of venue Conclusion and Prayer .. Certificate of Servic