Case Information
*1 TR.Ct. No. 201202293-W1 Carot of Criminal Ambass 48, 289-08
Findings of Facts For the Court to Counsider.
Now Comes Reynaud Provisís of Applicant in the above stiyled and numbered Cause, and would show the following
I.
- Aativant Argues that the Findings of Facts, and Conclusions of Law Presented by the 200th Subtotal District Court of Reve County Texas, Signed by the Honorsby Judge Melis A Sivonel, is not accurate and misleading to the Court of Criminal Appeals.
A. Iveffective assistance of Counsel:
Trial Counsel has a duty to make Adequate Investigation; Also Counsel has a duty to make proper investigation and Before fore rival, See Exmente Dunham 650 Siv. 2d 825-527, Tex. Cilm. April 1983.
RECEIVED IN COURT OF CRIMINAL APPEALS NOV 032015
ADOIADOSIS, Clorix
*2
- An Economic decision to not fully investigate is neither a strategic nor reasonable decision. Ex Parle Briggs-187. SW. 3d, H58-467-468.(Tex.cim App. 2005). C. Counsels failure to show a legitimate Subpoe or Process of witness Juan Rosas who was the Driwe of the vehicle on the night of NOV. 112011 , is a violation of 6 th Amendment Compulsory Process. D. Applicant Argues that he sent 2 letters of Compiaids to the Monorable Judge Melis Skirmer. letters dated october 15 f 2012, and January 13, 2013, See Exhibits-A and B. in Applicants Memorandum of Law Preseted with his Post-covidion wlit, Also Exhibits weemailed to the Horwable Abel Acosta, clerk of Court ofCriminal Appeals Oct. . E. Applicant Argues he Pleaded for 6 months with the 290th District Court fo a inlest gation to collect valuable in for mation convening the traffic stop, and citations written by S.A.P.D. Officers who made the illegal stop, search of cell phone, and search of Person. See Exhibits A- B-C.
*3 F. Applicant Argues that the only Police Report written to the incident and arrest, is listed as Exhibit-D also presented in the Original Post Conviction w/17 Ant. 1107 fitted with the District Clerk November 19th 2014, and also sent to Court of Criminal Appeals Clerk Abel Acosta on October 29th 2015.
2ndcol. 4. This offense Report written by offired Felipe Ramos is evidence that he did not search Applicant and that W-1 who is offired D. Tritley's 63, Question, search applicants cell phone and Search Applicants coat, and body and found a 40 caliber handgun.
2.1 1. Counsel James V. Tocci was ineffective for Not Filing a Pre-Trial Healing Motion, to argue the Motion to Suppress that was filed August 3rd 2012, due to the violations of Applicants 4th 5th 6th 14th 4 meant meet Right, indeed the 11 noted States Constitution.
2.2 Applicant Argues that for months the Court Appointed attorney Refuse to visit Applicant or Exceft his phone calls; and would never ask the 290th Court for a Investigator, neither did he file a whit of Subpoena for witness Suwless.
*4
Argument of Facts
- Applicant A figures that a criminal defendant is not allow access to all Insestigation Reports Made by the states attorney of Arresting offices, and that the 0 Nity of Fense Report wOitten by officers on the scene that was available to the Public is ErhibitD. which is of fense Report wridtew by of fliced felipe lannos who did not find the weapon of Make the Arvest...
Con Clusions of Law
- StW Antonio Texas Police Department Manual is available, they west. Law interest services. Rule 416 states that the offices who makes the arvest must file a Profeu Report, these Rules are govern by. Texas Local Government codese 143,051 , sec. 143,006 , sec. 311,005 , Malking the Rules and Regulations Promugated by police. upon the Com- Pletion of certain Procedural Steps, Also officers violating these Rules, violates the laws of the state of Texas.
*5
Praxie
Interefore Premises Considéted
Applicant Prans to the Court of Criminal Aopeats for Relief tom this illegal confinement to face the or ininal indidment of order the 250th District Court Judge MelisA shiowe for a Evidentiary hearing to Produce the of fense Reports by office D. Tritley 0563 to upheld Applicants 5th 14th Amendment Rights to Due Process and a Fundamentally Fair Trial.
Ramenhans
Pro-ge
LUSsWON Oeclavation,
I Rzymand Doviely R state that the following statements are True and
out