*1 CAUSE NO. 01-13-00415-CR, 01-13-00416-CR, 01-13-00417-CR
JAVIER NOEL CAMPOS Petitioner
VS.
THE STATE OF TEXAS Respondent
MOTION FOR REHEARING PURSUANT TO TRAP RULE 49.1 TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, JAVIER NOEL CAMPOS, Petitioner in the above entitled and numbered cause and respectfully moves this Honorable Court to order a new hearing pursuant to TRAP Rule 49.1 and would show the Court the following:
I
Petitioner filed a timely notice of appeal. Petitioner filed his Appellant brief on April 15, 2014 and the State filed the Appelle brief on September 5, 2014 The Court affirmed Petitioner's conviction and issued it's opinion on January 13, 2015.
II
The State, in it's brief, misconstrued the facts and law to the Court and painted a false factual picture that contributed to the Court's ruling.
III
The Court has made it's ruling against established state and federal law in a way that conflicts with the applicable decisions of the Court of Criminal Appeals and the Supreme Court of the United States.
IV
The Court's ruling is a denial of fundamental and Constitutional rights that result in a miscarriage of justice.
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PRAYER
WHEREFORE, PREMISES CONSIDERED, Petitioner respectfully prays that this Honorable Court order a new hearing pursuant to TRAP Rule 49.1 to reconsider Petitioner's grounds for appeal.
CERTIFICATE OF SERVICE
I, Javier N. Campos, certify that a true and correct copy of the foregoing Motion was mailed to the Harris County District Attorney, 1201 Franklin, Suite 600, Houston, Texas 77002 on this 26th day of January, 2015.
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Clerk Court of Appeals First Judicial District Houston, TX.
Re: Motion for Rehearing
Dear Clerk:
Enclosed please find Motion for Rehearing pusuant to TRAP Rule 49.1. Please file the motion and bring it to the attention of the Court for consideration. Also, please find one copy and date-stamp it and return it to me in the SASE. If you have any questions please feel free to contact me at anytime at the address above.
Thank you for your time and assistance.
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