Turner, Bowen – 2023, Jan 23 – Initial Reply Brief from Appellant

Initial Reply Brief filed on behalf of Appellant Victim C.B. on January 23, 2023 with the SC Court of Appeals with the argument:

“I. The right to present is not disputed.
II. This appeal was properly filed as a constructive writ of mandamus.
III. The proper timing of a petition for a writ of mandamus is at issue.
IV. Review is necessary to safeguard constitutional rights.
V. Victim was prejudiced by the trial court’s refusal to allow her to present before the guilty plea was accepted.”