EXHIBIT I

DEFENDANT'S WRITTEN REQUEST FOR NOTICE OF STATE'S INTENTION TO USE EVIDENCE OF EXTRANEOUS OFFENSES AT TRIAL

Defendant, John Doe makes this written request pursuant to Texas Rules of Evidence 404(b ), 609(f), 803, 804, 902, and Articles 37.07, 38.37, and 38.371, of the Texas Code of Criminal Procedure, and in accordance with the Standing Discovery Control Order for the * * *1h Judicial District Court of**** and******** Counties.

In furtherance of said request the Defendant would show the following:

RULE 404(a) AND (b)

John Doe requests that the attorney for the State of Texas to give reasonable pre-trial notice of the State's intent to use evidence of crimes, wrongs or acts pursuant to TRE 404(a) and (b)

This request is made for the State to give the requested notice in accordance with the Standing Discovery Control Order, as referenced herein. The request for notice includes the discovery of all evidence that the State has that would be used to establish each prior crime, wrong, or act.

Rule 609

John Doe requests that the attorney for the State of Texas to give notice of the State's intent to use, pursuant to Rule 609 of the Texas Rules of Evidence, evidence of any prior convictions which the State may seek to introduce to impeach the credibility of Defendant.

This request is made for the State to give the requested notice in accordance with the Standing Discovery Control Order, as referenced herein. This request includes the discovery of any supporting documentation regarding such prior convictions.

RULES 803, 804, AND 902

John Doe requests that the attorney for the State of Texas to give notice of the State's intent to use any records , documents or other evidence pursuant to Rules 803 , 804 and 902 of the Texas Rules of Evidence , which the State may seek to introduce in this cause.

This request is made for the State to give the requested notice in accordance with the Standing Discovery Control Order, as referenced herein. This request includes complete copies of any such documents or records and any supporting documentation.

Defendant further requests a reasonable opportunity to investigate whether the preparation or sources of the information, or any other circumstances concerning the proposed evidence , indicate a lack of trustworthiness.

ARTICLE 37.07, EVIDENCE OF PRIOR CRIMINAL RECORD IN ALL CRIMINAL CAUSES AFTER A FINDING OF GUILT

John Doe requests that the attorney for the State of Texas to give notice of the State's intent to use any items and/or evidence pursuant to Article 37.07 , Sec . 3, of the Texas Code of Criminal Procedure , that constitute evidence of, the prior criminal record of the Defendant, his general reputation , his character, and opinion regarding his character, the circumstances of the offense for which he is being tried , any extraneous crimes , wrongs or acts which may apply and be used and introduced into evidence by the State , in the punishment phase of the Defendant's trial , under Article 37 .07 , Sec. 3 , of the Texas Code of Criminal Procedure.

This request is made for the State to give the requested notice in accordance with the Standing Discovery Control Order, as referenced herein. This request includes complete copies of any such documents or records and any supporting documentation.

ARTICLE 38.37 EVIDENCE OF EXTRANEOUS OFFENSES OR ACTS

John Doe requests that the attorney for the State of Texas to give notice of the State's intent to use any items and/or evidence pursuant to Article 38.37 , Sections (1) and / or Sections (2) , of the Texas Code of Criminal Procedure , in accordance with the notice provision of Article 38.37 , that constitute evidence of any extraneous crimes , wrongs or acts which may apply to the above-styled and numbered cause , by reason of the criminal offense charged against Defendant, which criminal offense is listed under Sections (1) and / or (2) of Article 38.37 , as specifically enumerated below:

(1) Chapter 21 (Sexual Offenses);

(2) Chapter 25.02 (Prohibited Sexual Conduct) ;

(3) Chapter 22 (Assaultive Offenses) ;

(4) Section 43.25 (Sexual Performance by a child); or

(5) An attempt or conspiracy to commit an offense listed in Section 1 of Article 38.37 of the Texas Code of Criminal Procedure.

This request is made for the State to give the requested notice in accordance with the ***th Judicial District Court ' s Standing Discovery Control Order. This request includes complete copies of any such documents or records and any supporting documentation.

ARTICLE 38.371 EVIDENCE

John Doe requests that the attorney for the State of Texas to give notice of the State's intent to use any items and / or evidence pursuant to Article 38.371 , at least 10 days before trial.

This request is made for the State to give the requested notice in accordance with the *** th Judicial District Court's Standing Discovery Control Order. This request includes complete copies of any such documents or records and any supporting documentation.

This written request regarding the above styled and numbered cause and Defendant named herein , as delivered to the *** 1h Judicial District Attorney ' s Office is intended to request that the State give reasonable notice (as specifically requested and described herein) , to the Defendant, pursuant to the ***th Judicial District Court ' s Standing Discovery Control Order.

Respectfully submitted,

Law Offices of JESKO AND STEADMAN

612 Earl Garrett Street

Kerrville, Texas 78028

Telephone: (830) 257-5005

Facsimile: (830) 896-1563

E-mail: jesk sted @ ktc.com

Clay B. Steadman

State Bar No. 00785038

Attorney for John Doe

Certificate Of Service

This is to certify that on , 2017 , a true and correct copy of the Defendant ' s Written Request for Notice of State's Intention to Use Evidence of Extraneous Offenses at Trial was served on the *** th Judicial District Attorney's Office , by facsimile.

Via Facsimile N o. (***) ***-****

Name of District Attorney

*** th District Attorney ' s Office

Address Line 1

Address Line 2

Clay B . Steadman