Theresa Balboa

Filed21July08A11:56
MarilynBurgess-DistrictClerk
HarrisCounty
EA001_877417
By:ALVAREZ,JENIFER
THE STATE OF TEXAS D.A. LOG NUMBER: 2754593
VS. CJIS TRACKING NO.:
THERESA RAYE BALBOA SPN: 02494025 AGENCY:HPD
DOB: W F 02/17/1992 O/R NO: 070885221
DATE PREPARED: 07/08/2021 ARREST DATE: 07/06/2021
NCIC CODE: 0908 49 RELATED CASES: 1725570; 1728274

FELONY CHARGE: Capital Murder
CAUSE NO: 173052201010 003 COURT ORDERED BAIL: Referred to (15.17)

HARRIS COUNTY DISTRICT COURT NO: 174 PRIOR CAUSE NO: 1699950
FIRST SETTING DATE: 7/12/2021 CHARGE SEQ NUM: 1
IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:
Before me, the undersigned Assistant District Attorney of Harris County, Texas, this day appeared the undersigned affiant, who under oath says
that he has good reason to believe and does believe that in Harris County, Texas, THERESA RAYE BALBOA, hereafter styled the
Defendant, heretofore on or about May 12, 2021, did then and there unlawfully, intentionally and knowingly cause the death of S.O.,
hereinafter called the Complainant, an individual under ten years of age, by striking the Complainant with a blunt object.
It is further presented that in Harris County, Texas, THERESA RAYE BALBOA, hereafter styled the Defendant, heretofore on or about
May 12, 2021, did then and there unlawfully, intentionally and knowingly cause the death of S.O., hereinafter called the Complainant, an
individual under ten years of age, by striking the Complainant against a blunt object.
AGAINST THE PEACE AND DIGNITY OF THE STATE.
Signed and sworn by me on 07/08/2021 Duly attested by me on 07/08/2021________
April Swan Brigida Pirra

AFFIANT Assistant District Attorney
Harris County District Attorney’s Office
TBC No. 24000110
PIRRA_BRIGIDA@DAO.HCTX.NET
COMPLAINT
D.A. LOG NUMBER: 2754593

DEFENDANT: THERESA RAYE BALBOA Page 1 of 1
173052201010 / Court: 174
Filed21July08A11:56
HarrisCounty
EA001_877417
By:ALVAREZ,JENIFER
CAUSE NO. 173052201010 003 2754593 1
THE STATE OF TEXAS § IN THE 174th DISTRICT COURT

§
VS. § OF
§
BALBOA, THERESA RAYE § HARRIS COUNTY, TEXAS
STATE’S MOTION FOR BOND CONDITIONS
COMES NOW, THE STATE OF TEXAS, by and through its Assistant District Attorney
and moves this Honorable Court to enter the following bond conditions:
 State requests the Defendant, whether a foreign national or not, be ordered to surrender
any and all passports, visas, or other travel documents and be prohibited from
obtaining or applying for any new or supplemental passport, visa, or travel document.
 State requests the Defendant have no contact with the Complainant in this case or
anyone in complainant’s household, including siblings and parents, in person or
through any other person, telephonically, by mail, or by any other manner or means,
for the duration of this cause and the following individual(s) and/or location(s):
Benjamin Rivera; Dalton Olsen, Sarah Olsen, and any member of Complainant's
family; Dylan Walker
 State requests the Defendant not possess any firearms, ammunition, or other weapons.
 State requests the Defendant submit to random urinalysis.
 State requests the Defendant be prohibited from using, possessing, or consuming any
alcohol, controlled substance, dangerous drug, or marijuana unless prescribed pursuant
to a lawful prescription issued by a medical doctor.
 State requests the Defendant submit to electronic monitoring by signing the contractual
agreements and complying with any stipulated curfews and rules.
 State requests the Defendant not have any contact with any minor child under the age
of seventeen (17) years of age, for any reason, except as specifically permitted by the
Court.
 State requests the Defendant not reside, go in, on or within one-thousand (1,000) feet
of a premises where children commonly gather, including but not limited to: schools,
day-care facilities, except as specifically permitted by the Court. The measurement of
the distance between the residence of the Defendant and the premises where children
gather shall be measured using the shortest, direct, straight line from the property line
of the Defendant’s residence to the property line of the premises where children
commonly gather.
 State requests the Defendant not supervise or participate in any activity or program that
includes participants or recipients who are seventeen (17) years of age or younger for
any reason, except as specifically permitted by the Court.
Respectfully submitted,
Cause No: 173052201010 Defendant: BALBOA, THERESA RAYE

STATE’S MOTION FOR BOND CONDITIONS - Page 1 of 3
Brigida Pirra
Assistant District Attorney
TBC No. 24000110
PIRRA_BRIGIDA@DAO.HCTX.NET

CERTIFICATE OF SERVICE
I, Brigida Pirra, the undersigned attorney, hereby certify that a true and correct copy of the
State’s Motion for Bond Conditions was e-mailed to counsel for the Defendant (if any such
counsel existed as attorney of record) on this date by electronic service using his State Bar of
Texas official address for electronic service.
Brigida Pirra

CAUSE NO. 173052201010 003 27545931

§
VS. § OF
§
ORDER ON STATE’S MOTION FOR BOND CONDITIONS
On , the State’s Motion for Bond Conditions was heard and having considered the
Motion it is GRANTED; therefore, the Conditions requested in the Motion and detailed herein
are ORDERED as Conditions of the Defendant’s Bond.
Further, the Court has explained the Conditions to the Defendant, who has affirmatively
acknowledged their understanding of these Conditions.
Conditions GRANTED:
Defendant, whether a foreign national or not, is ordered to surrender any and all passports,
visas, or other travel documents and is prohibited from obtaining or applying for any new or
supplemental passport, visa, or travel document.
Defendant shall have no contact with the Complainant in this case or anyone in
complainant’s household, including siblings and parents, in person or through any other person,
telephonically, by mail, or by any other manner or means, for the duration of this cause and the
following individual(s) and/or location(s):
Benjamin Rivera; Dalton Olsen, Sarah Olsen, and any member of Complainant's family; Dylan
Walker
Defendant shall not operate any motor vehicle without a properly installed and operating
ignition interlock device and in the absence of such device is prohibited from driving or operating
any motor vehicle.
Defendant shall not possess any firearms, ammunition, or other weapons.
Defendant shall submit to random urinalysis.
Defendant is prohibited from using, possessing, or consuming any alcohol, controlled

substance, dangerous drug, or marijuana unless prescribed pursuant to a lawful prescription issued
by a medical doctor.
Defendant shall submit to electronic monitoring by signing the contractual agreements and
complying with any stipulated curfews and rules.
Cause No: 173052201010, Defendant: BALBOA, THERESA RAYE

ORDER ON STATE’S MOTION FOR BOND CONDITIONS - Page 1 of 2
Defendant shall submit to GPS monitoring by signing the contractual agreements and
complying with any stipulated curfews and rules.
Defendant is subject to curfew and Defendant shall remain at home between the hours of
and .
Defendant shall not have any contact with any minor child under the age of seventeen (17)
years of age, for any reason, except as specifically permitted by the Court.
Defendant shall not reside, go in, on or within one-thousand (1,000) feet of a premises
where children commonly gather, including but not limited to: schools, day-care facilities, except
as specifically permitted by the Court. The measurement of the distance between the residence of
the Defendant and the premises where children gather shall be measured using the shortest, direct,
straight line from the property line of the Defendant’s residence to the property line of the premises
where children commonly gather.
Defendant shall not supervise or participate in any activity or program that includes
participants or recipients who are seventeen (17) years of age or younger for any reason, except as
specifically permitted by the Court.
Defendant is forbidden from possessing or accessing any of the following: 1) any computer
or cell phone with the ability to access the internet; 2) the Internet; 3) pornography of any kind.
Defendant is prohibited from the following:

Signed on .
Magistrate / Judge Presiding
BALBOA, THERESA RAYE

DEFENDANT
Cause No: 173052201010, Defendant: BALBOA, THERESA RAYE

ORDER ON STATE’S MOTION FOR BOND CONDITIONS - Page 2 of 2
Filed21July08A11:56
HarrisCounty
EA001_877417
CAUSE NO. 173052201010 003 2754593 1 By:ALVAREZ,JENIFER

§
VS. § OF
§
MOTION FOR A “PROOF EVIDENT” HEARING

TO DENY BAIL FOR A CAPITAL OFFENSE
THE STATE OF TEXAS, by and through her Assistant District Attorney of Harris
County, files this Motion for a “Proof Evident” Hearing to Deny Bail for a Capital Offense and
shows the following:
The defendant is charged with a capital offense. The State moves for a “proof evident”
hearing to demonstrate by “clear and strong evidence” that the defendant is not entitled to bail by
sufficient sureties prior to indictment. TEX. CONST. ART. 1, §11.
RESPECTFULLY SUBMITTED,
Brigida Pirra
TBC No. 24000110
pirra_brigida@dao.hctx.net
I, the undersigned attorney, hereby certify that a true and correct copy of this instrument
was e-mailed to counsel for the Defendant on this date by electronic service using his State Bar
of Texas official address for electronic service.
Brigida Pirra
TBC No. 24000110
CAUSE NO. 173052201010 003

§
VS. § OF
§
ORDER
Having considered the State’s Motion for a “Proof Evident” Hearing to Deny Bail for a
Capital Offense, and evidence presented at the “proof evident” hearing, the Court FINDS the
State has presented “proof evident” by “clear and strong evidence” that: (1) an offense was
committed, (2) the accused is the guilty agent, and (3) he would probably be punished by the death
penalty if the law is administered. Beck v. State, 648 S.W.2d 7, 9 (Tex. Crim. App. 1983).
The defendant is DENIED BAIL pending indictment. The defendant may be subject to
bail after indictment upon examination of the evidence, in such manner as may be prescribed by
law. TEX. CONST. ART 1, §11.
SIGNED AND ENTERED on .
Judge Presiding
Harris County, Texas
Filed21July12A11:52
HarrisCounty
Pgs-1
OTMSW
7/13/2021 11:23 AM
Marilyn Burgess - District Clerk Harris County
Envelope No. 55290990
By: E Henriquez
Filed: 7/13/2021 11:23 AM
CAUSE NO. 1730522
THE STATE OF TEXAS § IN THE DISTRICT COURT OF

§
VS. § HARRIS COUNTY, T E X A S
§
THERESA RAYE BALBOA § 1 7 4 T H J UDICIAL D I S T R I C T
ORDER TO
RESTRICT VISITATION AND INTERVIEWS
CAME TO BE HEARD THIS DATE, defense counsel’s request to restrict and limit
visitation and interviews of inmate THERESA RAYE BALBOA, SPN NO. 02494025 and the court
having considered the request of defense counsel is of the opinion it should be GRANTED.
IT IS THEREFORE ORDERED, that the Harris County Sheriff’s Department shall limit
visitation and interviews of the inmate THERESA RAYE BALBOA, SPN NO. 02494025 to only
those individuals approved by the attorney of record ANTHONY OSSO. No other individuals shall
be permitted to visit with or interview this inmate without the prior written approval of Anthony
Osso.
Signed this the day of , 2021.
JUDGE PRESIDING
3/23/2022 3:44 PM
By: b dunn
Filed: 3/23/2022 3:44 PM
CAUSE NO. 1730522

§
§
MOTION FOR FUNDS FOR THE REVIEW

OF JAIL CALLS
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, THERESA RAYE BALBOA, defendant herein, by and through her attorneys
of record ANTHONY OSSO and LISA ANDREWS, and files this Motion for Funds for the
Review of Jail Calls, and for such cause would show the court as follows:
I.
Defendant stands charged with the felony offense of capital murder pursuant to Art. 19.03
of the Texas Penal Code. She is indigent and without funds to aid in any manner to her defense. Due
to her indegency, this court has heretofore appointed counsel to provide legal representation in this
case. Defendant has been incarcerated in the Harris County Jail since June 4, 2001 awaiting trial
which is set to begin February 20, 2023. Pursuant to Art 39.14 of the Texas Code of Criminal
Procedure the State of Texas will serve counsel with approximately 1 3/4 years of jail calls relating
to this case on disc. Therefore, it is apparent that the review of these discovery materials received
would be exhaustive, overwhelming and costly to accomplish without outside assistance.
II.
In order to ensure that defendant’s constitutional rights to a fair trial, due process, equal
protection and effective assistance of counsel are fully protected, it is imperative that the discovery
materials are reviewed by the defense team in preparation for trial.

III.
By this motion, defense counsel is requesting funds to hire outside assistance to review the
jail calls. Elizabeth Huerta is a young attorney with experience in reviewing and evaluating jail calls.
She is available to preform this task at a reduced rate to the county. Based on her education (Juris
Doctorate) and criminal law experience, she is qualified to assist defense counsel with reviewing the
jail calls and is willing to do so at the reduced rate of $75.00 per hour (which is ½ counsel’s hourly
rate). Due to the requirements of their ongoing practices, defendant’s attorneys are unable to review
the discovery without the outside assistance requested.
WHEREFORE PREMISES CONSIDERED, defendant requests this court grants this motion
and authorizes the funds necessary to hire outside assistance to review the jail calls in her case.
Respectfully submitted
/S/ ANTHONY OSSO
ANTHONY OSSO
TBA #: 15336800
1125 Lyric Centre
440 Louisiana
Houston, Texas 77002
(713) 225-4444
/S/ LISA ANDREWS
LISA K. ANDREWS
TBA # 24000676
1207 S. Shepherd
(713) 523-7878
(713) 523-7887 Facsimile
ATTORNEYS FOR DEFENDANT
2
CAUSE NO. 1730522

§
§
ORDER
MOTION FOR FUNDS FOR THE REVIEW
OF JAIL CALLS
CAME TO BE HEARD Motion for Funds for the Review of Jail Calls and the court
having considered said petition and argument of counsel is of the opinion it should be GRANTED.
IT IS THEREFORE ORDERED, that the defendant shall have funds at a rate of $75.00 per
hour to retain the services of Elizabeth Huerta to review jail calls in this case.
This court recognizes that there will be jail calls spanning more than 1 3/4 years to be
reviewed and authorizes $4,500.00 for this service. Should review of the jail calls require out of court
hours in excess of this limit the court is to be advised accordingly.
IT IS FURTHER ORDERED that Elizabeth Huerta shall be paid for this service by the Harris
County Auditor’s Office upon submission of an invoice approved by this court.
Signed this the day of , 2022.
JUDGE PRESIDING
3
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Filed22June10P3:28
HarrisCounty
EA001_1330528
By:FAYALA
Filed22August19A11:39
HarrisCounty
SUP125162_921363
NO. 1730522 By:FAYALA
THE STATE OF TEXAS § IN THE 174TH CRIMINAL
VS. § DISTRICT COURT OF
THERESA BALBOA § HARRIS COUNTY, TEXAS
ATTACHMENT TO SUBPOENA DUCES TECUM
Houston Independent School District (HISD) Custodian of Records

4400 West 18th St., Building B
Houston, TX 77092
**** **** Please provide any and all education records maintained by HISD or by an individual or
entity acting for HISD that contains information directly related to Theresa Balboa (DOB: 02/17/1992) for the
years 1996-2008.
Education records include, but are not limited to, school health records; a student’s social security number;
student’s identification number, academic work completed; level of achievement records including grades, grade
point average (GPA) and standardized achievement test scores; interim reports; enrollment documents;
transcripts; academic improvement plans; intervention records; attendance data; evaluation reports that include
standardized intelligence, aptitude and psychological test results; interest inventory results; Exceptional Student
Education (ESE) files; disciplinary records, including suspension and expulsion records; family biographical
background information; parent/teacher conference reports; 504 plan participation and details; special program
eligibility; teacher or counselor ratings and observations; verified reports of serious or recurrent behavior
patterns; records used in expulsion hearings; and any other evidence, knowledge, or information recorded in any
medium, including but not limited to, handwriting, typewriting, print, magnetic tapes, film, computer media,
video or audio tape, microfilm and microfiche, and digital records. Psychological files (including psychological
evaluations created and/or maintained by school district staff); therapy and counseling records (including
psychosocial assessments, therapeutic treatment plans, and therapy progress notes created and/or maintained by
school district staff); and school (guidance) counseling records are also education records protected under
FERPA as well as state laws.
Please include a Business Records Affidavit, including but not limited to whether there are nonresponsive
records available.
****You may comply with this subpoena by making copies available, or emailing the records to Amy A.
Cone at aacinvestigate@gmail.com. For specific questions regarding the request, please contact Amy A. Cone at
(832) 687-8076, or contact the attorney at the address listed below.
ATTORNEY
Lisa K. Andrews
1207 S. Shepherd
SBN 24000676
Tel 713-523-7878
lisa@lisaandrewslaw.com
SEALED VOUCHER
SEALED VOUCHER
1/5/2023 3:58 PM
By: N Shankle
Filed: 1/5/2023 3:58 PM
CAUSE NO. 1730522

§
§
MOTION FOR THE COURT TO DIRECT COURT

REPORTER TO TAKE VOIR DIRE EXAMINATION, OPENING
STATEMENTS, BENCH CONFERENCES, AND ALL FINAL ARGUMENTS
of record ANTHONY OSSO and LISA ANDREWS, and respectfully moves this Honorable Court
to instruct the Court Reporter of this Court to record the entire voir dire examination of the jury
panel, opening statements, all bench conferences and all final arguments in this case in addition to trial
testimony.
WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that the Court
grant this Motion in all things, and instruct the Court Reporter to transcribe jury selection, opening
statements, all bench conferences, and final arguments in this cause in addition to trial testimony.
Respectfully submitted:
/S/ ANTHONY OSSO
ANTHONY OSSO
TBA #: 15336800
1730 Lyric Centre
440 Louisiana
(713) 225-4444
/S/ LISA ANDREWS
LISA K. ANDREWS
TBA # 24000676
1207 S. Shepherd
(713) 523-7878
(713) 523-7887 Facsimile
I, ANTHONY OSSO hereby certify that a true and correct copy of the above Motion for
the Court to Direct Court Reporter to Take Voir Dire Examination, Opening Statements,
Bench Conferences, and all Final Arguments has been forwarded on this day of
, 2023 to:
Janna Ozwald
Ozwald_Janna@dao.hctx.net
/S/ Anthony Osso
ANTHONY OSSO
CAUSE NO. 1730522

§
§
ORDER
MOTION FOR THE COURT TO DIRECT COURT
REPORTER TO TAKE VOIR DIRE EXAMINATION, OPENING
STATEMENTS, BENCH CONFERENCES, AND ALL FINAL ARGUMENTS
On this _____ day of ________________, 2023, came to be heard the Motion for the Court
to Direct Court Reporter to Take Voir Dire Examination, Opening Statements, Bench
Conferences, and all Final Arguments in addition to trial testimony, and after due consideration,
the Court is of the opinion, and it is hereby ORDERED that said Request is:
______________________ GRANTED
______________________ DENIED, to which ruling Defendant timely excepts.
SIGNED this the day of , 2023.
JUDGE PRESIDING
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Anthony Osso on behalf of Anthony Osso

Bar No. 15336800
AnthonyOssoAtty@msn.com
Envelope ID: 71529544
Status as of 1/5/2023 5:17 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Janna Ozwald Ozwald_Janna@dao.hctx.net 1/5/2023 3:58:10 PM ERROR

1/5/2023 3:58 PM
By: N Shankle
Filed: 1/5/2023 3:58 PM
CAUSE NO. 1730522

§
§
MOTION TO COMPEL DISCLOSURE OF

EVIDENCE FAVORABLE TO THE DEFENDANT
of record ANTHONY OSSO and LISA ANDREWS, and requests that the court compel the state
to disclose any and all evidence favorable to the defendant including the following:
1. Any and all evidence showing the defendant’s lack of culpability; and
2. Any and all evidence reflecting on the issue of punishment favorably to the defense.
WHEREFORE, PREMISES CONSIDERED, the defendant prays and requests that the court
grant items 1 and 2.
Respectfully submitted:
/S/ ANTHONY OSSO
ANTHONY OSSO
TBA #: 15336800
1125 Lyric Centre
440 Louisiana
(713) 225-4444
/S/ LISA ANDREWS
LISA K. ANDREWS
TBA # 24000676
1207 S. Shepherd
(713) 523-7878
(713) 523-7887 Facsimile
I, ANTHONY OSSO hereby certify that a true and correct copy of the above Motion to
Compel Disclosure of Evidence Favorable to the Defendant has been forwarded on this day
of , 2023; to:
Janna Ozwald
/S/ Anthony Osso
ANTHONY OSSO
CAUSE NO. 1730522

§
§
ORDER
MOTION TO COMPEL DISCLOSURE OF
EVIDENCE FAVORABLE TO THE DEFENDANT
On this _____ day of ________________, 2023, came to be heard the Motion to Compel
Disclosure of Evidence Favorable to the Defendant, and after due consideration, the Court is of
the opinion, and it is hereby ORDERED that said Request is:
______________________ GRANTED
______________________ DENIED, to which ruling Defendant timely excepts.
SIGNED this the day of , 2023.
JUDGE PRESIDING

Bar No. 15336800
Case Contacts

1/5/2023 3:58 PM
By: N Shankle
Filed: 1/5/2023 3:58 PM
CAUSE NO. 1730522

§
§
DEFENDANT'S MOTION TO ELECT PUNISHMENT
NOW COMES THERESA RAYE BALBOA, defendant herein, by and through her attorneys
of record ANTHONY OSSO and LISA ANDREWS, and files this Defendant's Motion to Elect
Punishment and for such cause would show the court as follows:
I.
Defendant is being tried for the offense of capital murder. In the event a jury returns a verdict
of guilty on any lesser offense, defendant elects the jury to assess punishment.
WHEREFORE PREMISES CONSIDERED, defendant prays this court grant this motion and
order the jury to assess punishment should a verdict of guilty be rendered in this case.
/S/ ANTHONY OSSO
ANTHONY OSSO
TBA #: 15336800
1125 Lyric Centre
440 Louisiana
(713) 225-4444
/S/ LISA ANDREWS
LISA K. ANDREWS
TBA # 24000676
1207 S. Shepherd
(713) 523-7878
(713) 523-7887 Facsimile
I, ANTHONY OSSO, do hereby certify that a true and correct copy of the foregoing
Defendant's Motion to Elect Punishment was forwarded this day of , 2023, to:
Janna Ozwald
/S/ ANTHONY OSSO
ANTHONY OSSO
2
CAUSE NO. 1730522

§
§
ORDER
DEFENDANT'S MOTION TO ELECT
PUNISHMENT
On this day of , 2023, came to be heard Defendant's Motion
to Elect Punishment and the court having considered said motion with argument of counsel is of the
opinion it should be GRANTED.
IT IS THEREFORE ORDERED that the jury shall assess punishment should a verdict of
guilty of a lesser offense be rendered in this case.
JUDGE PRESIDING
3

Bar No. 15336800
Case Contacts

1/5/2023 3:58 PM
By: N Shankle
Filed: 1/5/2023 3:58 PM
CAUSE NO. 1730522

§
§
DEFENDANT’S FIRST REQUEST FOR

SPECIFIC DISCOVERY MATERIALS
(WRITTEN OR RECORDED STATEMENTS)
NOW COMES, THERESA RAYE BALBOA, defendant herein, by and through her attorneys
of record ANTHONY OSSO and LISA ANDREWS, and pursuant to Article 39.14 of the Texas
Code of Criminal Procedure, the Due Process Clause of the Fourteenth Amendment to the United
States Constitution and Article I, § 19 of the Texas Constitution, files This Defendant’s First
Request for Specific Discovery Materials (Written or Recorded Statements), and for such cause
would show the court as follows:
I.
Defendant stands charged with the felony offense of capital murder. Trial is set to begin
February 20, 2023.
Defense counsel is in the process of preparing for trial and is in need of evidence requested
herein in a timely manner to endure that effective assistance of counsel can be provided.
Defendant moves the Court to instruct the prosecutor to make available before trial for her
attorneys’ inspection and copying any and all written and/or recorded statements either custodial or
otherwise made by defendant the state intends to use for any purpose at trial.
WHEREFORE, PREMISES CONSIDERED, defendant respectfully prays this court grant this motion
and establish a deadline for compliance.

/S/ ANTHONY OSSO
ANTHONY OSSO
TBA #: 15336800
1730 Lyric Centre
440 Louisiana
(713) 225-4444
/S/ LISA ANDREWS
LISA K. ANDREWS
TBA # 24000676
1207 S. Shepherd
(713) 523-7878
(713) 523-7887 Facsimile
I, ANTHONY OSSO, do hereby certify that a true and correct copy of the foregoing
instrument has been furnished to the State by email on the _____ day of _______, 23.
Janna Ozwald
/S/ Anthony Osso
ANTHONY OSSO
2
CAUSE NO. 1730522

§
§
ORDER
DEFENDANT’S FIRST REQUEST
FOR SPECIFIC DISCOVERY MATERIALS
(WRITTEN OR RECORDED STATEMENTS)
CAME TO BE HEARD, this day of 2023, the foregoing
Defendant’s First Request for Specific Discovery Materials (Written or Recorded Statements)
and the Court having considered said motion together with argument of counsel, is of the opinion that
said motion should be GRANTED and that the following materials shall be made available through
discovery:
1. Any and all written and/or recorded statements made by defendant custodial or
otherwise the state intends to use at trial for any purpose.
IT IS THEREFORE ORDERED, that the State comply with this order at least 21 days prior to trial.
JUDGE PRESIDING

Bar No. 15336800
Case Contacts

1/5/2023 3:58 PM
By: N Shankle
Filed: 1/5/2023 3:58 PM
CAUSE NO. 1730522

§
§
DEFENDANT'S REQUEST FOR

THE STATE TO PROVIDE DEFENDANT WITH
WRITTEN NOTICE OF ALL PRIOR CRIMINAL
CONVICTIONS AND BAD ACTS INTENDED
TO BE INTRODUCED DURING THE
GUILT/INNOCENCE AND PUNISHMENT PHASES OF TRIAL
of record Anthony Osso and Lisa Andrews, and files this DEFENDANT'S REQUEST FOR THE STATE TO
PROVIDE DEFENDANT WITH WRITTEN NOTICE OF ALL PRIOR CRIMINAL CONVICTIONS AND BAD ACTS
INTENDED TO BE INTRODUCED DURING THE GUILT/INNOCENCE AND PUNISHMENT PHASES OF TRIAL
and for such cause would show unto this honorable court as follows:
I.
Defendant stands charged with the felony offense of capital murder. In an effort to prepare
for trial, defendant’s attorneys are in need of notice from the state of all prior convictions and bad acts
of which it intends to introduce during the guilt/innocence and in the event necessary punishment
phases of trial.
II.
This request is being made to ensure that defendant’s rights to a fair trial, due process, cross
examination of witnesses, and effective assistance of counsel, under state and federal constitutions
and Texas Code of Criminal Procedure are fully protected.
WHEREFORE, PREMISES CONSIDERED, defendant requests the state provide the

defendant with written notice at least 21 days prior to trial of all prior convictions and bad acts it
intends to introduce during the guilt/innocence and in the event necessary punishment phases of trial.
Respectfully submitted,
/S/ Anthony Osso
ANTHONY OSSO
T.B.A. No. 15336800
440 Louisiana, Suite 1125
Tel: (713) 225-4444
Fax: (713) 222-1110
/S/ LISA ANDREWS
LISA K. ANDREWS
TBA # 24000676
1207 S. Shepherd
(713) 523-7878
(713) 523-7887 Facsimile
I, ANTHONY OSSO hereby certify that a true and correct copy of the above DEFENDANT'S
REQUEST FOR THE STATE TO PROVIDE DEFENDANT WITH WRITTEN NOTICE OF ALL PRIOR CRIMINAL
CONVICTIONS AND BAD ACTS INTENDED TO BE INTRODUCED DURING THE GUILT/INNOCENCE AND
PUNISHMENT PHASES OF TRIAL has been forwarded on this day of ,
2023 to:
Janna Ozwald
/S/ Anthony Osso
ANTHONY OSSO
2
CAUSE NO. 1730522

§
§
ORDER
DEFENDANT'S REQUEST FOR
THE STATE TO PROVIDE DEFENDANT WITH
WRITTEN NOTICE OF ALL PRIOR CRIMINAL
CONVICTIONS AND BAD ACTS INTENDED
TO BE INTRODUCED DURING THE
GUILT/INNOCENCE AND PUNISHMENT PHASES OF TRIAL
CAME TO BE HEARD, this day of , 2023, the foregoing DEFENDANT'S
REQUEST FOR THE COURT TO ORDER THE STATE TO PROVIDE DEFENDANT WITH WRITTEN NOTICE OF
ALL PRIOR CRIMINAL CONVICTIONS AND BAD ACTS INTENDED TO BE INTRODUCED AT TRIAL, and the
court having considered said request is of the opinion it should be GRANTED.
IT IS THEREFORE ORDERED, that the state shall provide defendant with written notice of all
prior convictions and bad acts with date, place, time, and complainant’s name if applicable, it intends
to introduce during the guilt/innocence and punishment phases of trial on or before the _______ day
of ________________, 2023.
JUDGE PRESIDING
3

Bar No. 15336800
Case Contacts

SEALED VOUCHER
Filed23February20P4:38
586360
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA HarrisCounty
SUP154261_673199
By:JGREEN
APPLICATION FOR SUBPOENA BY STATE FOR WITNESS IN THE DISTRICT COURT.
Brett Batchelor- February 20, 2023
CAUSE NO. 173052201010 003
THE STATE OF TEXAS IN THE 174 DISTRICT COURT

VS.. OF HARRIS COUNTY, TEXAS
THERESA RAYE BALBOA OFFENSE CAPITAL MURDER-UNDER TEN
YRS
1 Y Harris County
Please issue a subpoena in the above-styled cause for the following named witness(es) whose location and vocation in this State, as far
as known, I state below:
Custodian of Records c/o Legal Department1, Vocation: Unknown, Service Type: Peace Officer
Child Protective Services Dept. Of Family & Protective Services (Murworth), Yes
2525 Murworth Houston, TX 77054 Records@dfps.texas.gov , County: Harris
Officer Instructions: serve via email and include the confidential attachmentDo not serve by Cerified Mail. Duces Tecum, b1151c5e-39fd-
4eb0-8bc1-717699f594d4,
Special Instructions for Witness: Please provide any and all DFPS records (all counties), including but not limited to: summaries, narratives,
interviews, contact records, audio, video, and/or photographs, related to the family referenced in the attached document. Please produce said
records on a CD, DVD or other electronic format along with a completed business records affidavit.
Please provide this documentation by the date on this subpoena in lieu of appearance.
Please email records to: Kircus_heidi@dao.hctx.net1345128 true
IN: OFFENSE REPORT NUMBER: 070885221 C
if found in your county, to appear before the Honorable HAZEL B. JONES, IN THE 174 DISTRICT COURT, Harris County, Texas,
on 03/31/2023 at 8:45 A.M., to give evidence in behalf of the State and Defendant in the above styled cause wherein the State of Texas is
the Plaintiff and THERESA RAYE BALBOA is the Defendant, and to remain there from day to day, term to term until discharged by
the Court. The testimony of said witness(es) is believed to be material to the State.
Brett Batchelor
Assistant District Attorney 24090849
Harris County, Texas
713-274-5800
BATCHELOR_BRETT@dao.hctx.net
BATCHELOR_BRETT@dao.hctx.net
Filed23February20P4:38
HarrisCounty
SUP154261_673199
By:JGREEN

Theresa Balboa

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Filed21July08A11:56

NCIC CODE: 0908 49 RELATED CASES: 1725570; 1728274

CAUSE NO: 173052201010 003 COURT ORDERED BAIL: Referred to (15.17)

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:

AGAINST THE PEACE AND DIGNITY OF THE STATE.

Signed and sworn by me on 07/08/2021 Duly attested by me on 07/08/2021________

April Swan Brigida Pirra

D.A. LOG NUMBER: 2754593

THE STATE OF TEXAS § IN THE 174th DISTRICT COURT

STATE’S MOTION FOR BOND CONDITIONS

Cause No: 173052201010 Defendant: BALBOA, THERESA RAYE

Cause No: 173052201010 Defendant: BALBOA, THERESA RAYE

Cause No: 173052201010 Defendant: BALBOA, THERESA RAYE

THE STATE OF TEXAS § IN THE 174th DISTRICT COURT

ORDER ON STATE’S MOTION FOR BOND CONDITIONS

Defendant shall not possess any firearms, ammunition, or other weapons.

Defendant shall submit to random urinalysis.

Defendant is prohibited from using, possessing, or consuming any alcohol, controlled

Cause No: 173052201010, Defendant: BALBOA, THERESA RAYE

Defendant is prohibited from the following:

Magistrate / Judge Presiding

BALBOA, THERESA RAYE

Cause No: 173052201010, Defendant: BALBOA, THERESA RAYE

THE STATE OF TEXAS § IN THE 174th DISTRICT COURT

MOTION FOR A “PROOF EVIDENT” HEARING

shows the following:

sufficient sureties prior to indictment. TEX. CONST. ART. 1, §11.

THE STATE OF TEXAS § IN THE 174th DISTRICT COURT

law. TEX. CONST. ART 1, §11.

SIGNED AND ENTERED on .

CAUSE NO. 1730522

THE STATE OF TEXAS § IN THE DISTRICT COURT OF

Signed this the day of , 2021.

CAUSE NO. 1730522

THE STATE OF TEXAS § IN THE DISTRICT COURT OF

MOTION FOR FUNDS FOR THE REVIEW

TO THE HONORABLE JUDGE OF SAID COURT:

would be exhaustive, overwhelming and costly to accomplish without outside assistance.

materials are reviewed by the defense team in preparation for trial.

the discovery without the outside assistance requested.

/S/ ANTHONY OSSO

/S/ LISA ANDREWS

ATTORNEYS FOR DEFENDANT

THE STATE OF TEXAS § IN THE DISTRICT COURT OF

hours in excess of this limit the court is to be advised accordingly.

County Auditor’s Office upon submission of an invoice approved by this court.

Signed this the day of , 2022.

THE STATE OF TEXAS § IN THE 174TH CRIMINAL

VS. § DISTRICT COURT OF

THERESA BALBOA § HARRIS COUNTY, TEXAS

ATTACHMENT TO SUBPOENA DUCES TECUM

Houston Independent School District (HISD) Custodian of Records

CAUSE NO. 1730522

THE STATE OF TEXAS § IN THE DISTRICT COURT OF

MOTION FOR THE COURT TO DIRECT COURT

TO THE HONORABLE JUDGE OF SAID COURT:

/S/ ANTHONY OSSO

ATTORNEYS FOR DEFENDANT

/S/ Anthony Osso