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11 5001 Leal Garcia V Texas 0707 Supreme Court Supremecourt  Form

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Mr Shima would ask ask counsel in 125 685 state of Kansas versus Jose Garcia Martinez to please come forward may please Court I'm Ryan eninger appearing on behalf of Jose Garcia Martinez uh with the Court's permission I would like to reserve three minutes for rebuttal please thank you um they stud County jury convicted Jose Garcia Martinez of felony murder with the predicate felony of aggregated aggravated kidnapping he was also convicted of aggra aggravated battery along with a single count of simple battery uh Mr Garcia was then sentenced to life without the possibility of parole for 25 years first issue that um I've raised in this brief uh before the court this morning is that the evidence of trial was insufficient to prove both of the alternative means of taking and confining um Mr Hayden in this case in order to uh prove Beyond a reasonable doubt that the AG of the aggravated kidnapping and therefore his felony murder that conviction as well as his felony murder conviction uh shou

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