Case Information
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74,699.05
TO: Court of Criminal appeal of Texas P080Z 12308 CAPITOLISIATION AUSTIN, TEXAS 78711 FROM: Johnny Q. Clawson,Jr. 1578431 Terrell 1300 FM 655 Rosharon, Texas 77583
RE: 6th District Court Cause # 22971 HC_% Dear Sir or Madame, Enclosed is a copy of the rebuttal to the State's Answer to my Writ of Habeas Corpus 11.07. I received the State's answer at legal mail on 5 March, 2015 so I answered their answer the same day I received it. So please file the enclosed Petitioner's Rebuttal of States Answer. Please give me notice as to when this Rebuttal was filed.
Thank you for your time and effort in filing this rebuttal.
RECEIVED IN COURT OF CRIMINAL APPEALS WAR 112015
Abel Acosta, Clark
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CAUSE NO. 22971 HCS
COURT OF CRIMINAL APPEAL OF TEXAS
STATE OF TEXAS V. JOHNNY Q. CLAWSON,JR.
PETITIONER'S REBUTTAL OF STATES ANSWER
NOW COMES, Johnny Q: Clawson, Jr., Prosse pursuant to article 11.07 of the Texas Code of Criminal Procedure and files this rebuttal to States Answer to Petitioner's Application for Writ:of Habeas Corpus filed by Johnny Q. Clawson, Jr., the applicant.
In response to State's Answer to Petitioner's Application for Writ of Habeas Corpus 11.07, Petitioner restates that all 18 (eighteen) grounds raised on Petitioner's Writ of Habeas Corpus are all reversible constitutional errors with all having Supreme Court documentational rulings to support petitioner's position. Furthermore, ALL grounds does have a stated actioable grounds for relief. Petitioner does raise cognizable claims for Habeas relief as called for in Mc gain v. State, 67 S.W.3d 2 n 4 (Tex.Crim. App. 2002) which is satisfied since Petitioner raises: 1) ineffective assistance of Trial counse1; 2) prosecutorial misconduct; 3) judical abuse of discretional powers; 4; ineffective assistance of appellate counsel. All four (4) of these areas are areas of :t constitutional errors which is the basè of this Schlup styled Actual Innocense Claim. The constitutional errors covers 5th, 6th,
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and 14th admentment of the United States of America Constitution.
PETITIONER'S BRAYER
Petitioner prays this Court reads and rules in Petitioner's favor granting an aquittal or remands for a new trial to correct this gravious miscarriage of justice. Plus orders an evidentuary hearing to be held as petitioner petitioned for with the petitioner pyszically at hearing in person due to petitioner's heavy reli ance on lip reading to suppliment what he hears of sound thru his hearing aid.
Datad:
Johnny Q. Clawson, Jr., #1578431 C.T.Terrell Unit
1300FM655 Rosharon, Texas 77583
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the Petitioner's Rebuttal to State's Answer to Petitioner's Application for urit of Habeas Corpus was sent to District Attorney Gary Young at 119 N. Main St., Paris, Texas 75460, this day 5th day of March, 2015.