Case Information
*1 TEXAS COURT OF CRIMINAL APPEALS c/o ABLE ACUSTA, CLERK EAPITAL STATION P.O. BOX 12308
AUSTIN TEXAS 78711-2308
RE: PINK V. STATE; COURT of APPEND CAUSE NOS, 05-H-00877, 78, 79, 80-CR; TEX, COURT CRIM APPEALS NOS. PD-0776, 77, 78, 79-15
DEAR CIERIK,
PLEASE FIND ENCLOSED PETITIONERS' MOTION TO SUPPLEMENT PETITION FOR DISCRETIONARY REVIEW (APPENDIX) IN THE ABOVE STYLED CASE (6), WITH COPIES OF ALL ROSE MOTIONS FILED SINSE FEDURARY 3,2014. THIS REAUEST IS BEING MADE PERSUANT TO TX. RULE APP: PROC. RULE 68:10. PLEASE MORE TO THIS COURT THAT THERE ARE OTHER MOTIONS THAT WERE FILED PRO SE THAT HAVE NOT BEEN TUBNED OVER TO PETITIONER BY THE COURT OF APPEALS TO THIS DATE, THAT ARE PETTINENT TO THIS COURTS CONSIDERATION OF PETITION FOR DISCRETIONARY REVIEW. PLEASE FILE AND SUPPLEMENT THESE COPIES OF ROSE MOTIONS WITH THE APPENDIX OF THE PETITION IN THE ABOVE STYLED CASE (s) AND BRIXED THEM TO THE ATTENTION OF THIS COURT IN YOUR USUAL MANNER.
PETITIONER HUMADY REDUEST THE CLERK SERVE THE STATE PRoSECUTIVEY ATTORNEY ABOPY OF THESE DOCUMENTS BECEUSE THE PETITIONER HAS NO WAY TO RENDER ADDITIONAL COPIES AND THE DRUGAS CO. DISTRICT ARTY. HAS PREVIOUSLY BEEN SERVED THESE PRO SE MOTIONS.
SHOULD YOU HAVE ANY QUESTIONS OR CONKERNS IN THIS MATTER, PLEASE DO NOT HESTATE TO CONTACT PETITIONER AT THE ADDRESS BECON, THANK YOU FOR YOUR ASSISTANCE.
VEAV TRUEIV YOURS,
PREHIRAD PINK, ROSE A PASSER 7 MEC.IIEII UNIT 3001 SALTH EINILY DRIE OEEVIIIE TX 78102
RECEIVED IN COURT OF CRIMINAL APPEALS SEP 112015
Abel Acosta, Cierk
*2 IN, THE IN, CHURT OF CRIMINAL ARPRAIS AUSTIN TEAMS
RESHARD REATH PARK PERITIANGER V. THE STATE OF TEAMS RESPONDENT
FROM THE COURT OF APPRAIS ADS. 05-14-00877,78,79,80-CR DALIAS COURY TRIAL COURT CAUSE NOS F-09-55346, F-13-60732, F-13-60733, F-13-70123
MOTION REQUESITION, SUPPLEMENT OF PETITION FOR DISERCTIONARY REVIEW APPENDIX WITH COPIES OF PRO SE MOTIONS
TO THE HUNDERABLE JUDYES OF THE COURT OF CRIMINAL APPRAIS:
CONES NEW RESINACED KEITH PARK, PETITIONER PRO SE AND RESPECTFULLY REQUESST THIS COURT EPRANT HIS MOTION TO SUPPLEMENT. THE APPENDIX OF PREVIOUSLY FICED PETITION FOR DISCRETIONARY REVIEW, WITH COPIES OF PRO SE MOTIONS FROM FREURARY 3, 2015 TO PRESENT. IN SUPPORT APPRELANT WOULD SHOUL THE Following!
I. THESIS PRO SE MOTIONS AND OTHERS FICED WITH THE COURT OF APPRAIS, ARE ASSOLUTELY NECESSARY FOR THIS COURTS REVIEW AND CONSIDERATION OF THE PETITIONERS, PETITION FOR DISCRETIONARY REVIEW TO SHOUL THE PERITONIERS DELIFERENCE IN MAKING THE COURT OF APPRAIS AGARE OF ISSUES OF LOST/MISSING TRANSCRIPTS AND INCOMPLETE APPENDI AND NECESSITY FOR EUIDENTIARY HEARING TO RESOUE THESE ISSUES. ALSO, TO SHOUL THIS COURT, THE COURT OF APPRAIS DECISION TO IENOPE PROF OF EUIDENCE IN THE APPENDIXE REEOPH AND IN THE DALIAS COURTY JUDICIAL SUSSEN DICKET (EERTONIC) AND DENIAC OF "ALL" MOTIONS FICED ITY RETTIONER ADDRESSING, THESE ISSUES WITHOUT EXPLINATION OR REFRENCE TO AND ANY CERAL ANTHORITY OR CITIARY, FOR THEIR DENIALS OF "ALL" PRO SE MOTIONS.
II. PETITIONER PAYS THIS COURT EPRANT THIS MOTION TO SUPPLEMENT THE APPENDIX OF PETITION FOR DISCRETIONARY REVIEW REFORTS THIS COURT PRESENTLY AND PAYS THIS COURT WILL COMPET ALL OTHER PRO SE MOTIONS FROM THE COURT OF APPRAIS, THAT PROVE THE COURT OF APPRAIS WAS AGARE OF ISSUES OF LOST TRANSCRIPTS PERCE TO SUBMISSION OF
*3
The Substantively Defective Adoas Brief. CoRes of Ro se Motions are Attached.
Repetively Submitted ReEd Prs. Petitioner
Certificate of Service
I ceasily that 10 per of this motion was sent by u.s. Maic From the Meconnell Lolir 3001, South Eanily Drive, BeEunle Texas 78102 an 9/91/5. Addressed To: Counsell For The Appellec Michael R. Caselas Dukes Countr. Dist. ATH. Office 133 N. River Eeunl Blvd CE 19 Dukes IX 75207
*4 Appeal No: 05-14-0087746,05714-008780R 05-14-008790K,05-14-008800R
In the Court of Appeals at Dallas Texas Fifth District
Reginau Keim Pink Appellant
The state of Texas Appellate
FILED IN COURT OF APPEALS
FEB 08 2015
LISA MATZ CLERK 3th DISTRICT
Appeal of Cause Number: F-09-55346, F-13-60732, F-13-60733, F-13-72623. On Appeal from the 283rd Judicial District Court of Dallas County, Texas
Hon. Rick Magnis, Recsiding
Second Motion For Extension of time to file Appellants' Pro se Brief or Responce to Anders brief
To the Honorable Justices of the Court of Appeals:
Cames now Reginald Keim Pink, Appellant pro se and respectfully moves the Court to Extend the February 4th 2015 dead line for flying his brief or Responce by 30 Thirty Dovs. In support, Appellant would show the following:
I.
On June 27, 2014 the judge found Appellant guilty of Robbery. The Judge assessed punishment at Life Years Impressionment in the Texas Department of Criminal Justice
II.
On November 6, 2014, Appellant received notice by mail that his appeal Amency filed an Anders brief on his behalf and notice that Appellant had a right to file a plose brief or Responce to the Anders brief.
*5
In September 18, 2014 the Appellant Revend was this made available to Appellant. The deadline teaching Appellants' brief or Response is February 4, 2014
II.
This is the Appellants' second request for extension, Appellant is unable to meet deadline for the following reasons: Limited legal knowledge, thereby sharing down my research. Very limited access to Law Library to only a few hours a day in the past 50 days. Appellant also is in need of more time to secure evidence needed to assert my argument. The evidence has been Request ed in writing by many from the court of the district. clerk, but has not been received as of yet. I believe this evidence must be obtained before submitting my job to be brief or Response and I have also enlisted the help of my family in helping me secure this evidence as quickly as possible.
III.
For Persons stated above. Appellant respectfully. Request an additional (rupery 50) Days to complete the job to the response in summer of Appellants appeal.
III.
Appellant prays that the court grant this motion and extend the time to the appellants job to the response by rupery pays. Extending the deadline to March 9, 2015. Appellant at this time does not participate any further delay in submitting my job to be brief or response after this second extension.
Reportfully Submitted
Certificate of Service
I certify that a copy of this motion was sent by the U.S. Postal Mailbox (a) the McGunell Unit, 5001 Emily Drive in Erenville, Texas 78102 on 1-30-15 Addressed to: Counsel for Appellate
Michael R. Cissillars Dallas Co. District Address Office 133 N. Riverfeent. Eled L6 19 Dallas TX 75207
*6 Ms. Lisa Marz clerk of the 5th. Counr of Appeals 200 Commerce Street, Surre 200 Dallas Texas, 75202
Re: Counr of Appeals Number: 05-14-00 97.7-CR, 05-14-005599R, 05-14-008 79-CR, 05-14-00 880-CR
Trial Court Cause Number: F-09-55344, F-13-60732, F-13-60733, F-13-72123
Dear Modam, on November 6, 2004, My appeal Attorney notified me that an Anders brief was fitted on my behalf as outlined in Anders v. California and further advised me of my right to file a pro se brief or response to the Anders brief. By this letter, I am giving notice that I wish to file a pro se brief or response. I also Request an Extension of time in which to file my brief or response since I am not an A rtorney of Law, and the fact that I have had only limited time and opportunity to the law library in the past 30 days. Also, I need more time to secure evidence I need to assert my argument. This evidence has been requested in writing by mail, but not received as of yet. I believe this evidence must be obtained before submitting my pro se brief or response and I have also initiated the help of my family to help me secure this evidence as quickly as possible. Enclosed, please find my second motion for extension of time. Please file and bring to the attention of the court.
Thank you for your Consideration
Respectfully Reyentfully Appeant pro se
Reginald Prik R1438997 McConnell Unit 3001 South Emily Drive Deeville Ft. 78102
*7
*8 Ms Lisa Matz, CIFAR of the 5th COURT of Appeals 600 Commerce Street, Suite 200
Dallas TX, 75202
RECEIVED Court of Appeals Feburary 24, 2015 MAR n 32015
Lisa Matz Clerk, 5th District
Re: Court of Appeals Number: 0544-00877-CR, 05-14-00878-CR 05-14-00879-CR, 05-14-00880-CR
Trial Cause Number: F-0955346, F-13-60732 F-13-60733, F-13-72123
Dear Madam, on Feburary 10,2015, I received a letter dated Feburary 4, 2015 from the court of appeals notifying me that the court denied my request for a second exceration of time to secure Docker sheets and other evidence need to be presented to the Court of Appeals with my prior presence to the Anders Brief my counsel filed. The court also, notified me that the Appeals would be submitted in due course.
I would respectfully, like to take this opportunity to re-quest that the court prompts notify me of the date of submission of my cases, if in fact they have been set, and if no date has been set, I received no de Notified Assomas It is set for submission, since an Anders brief was filed and my appointed counsel will not be notifying me.
I thank you for your activation to this matter, present. would you please file this request and bring it to the attention of the court.
Thank you for your consideration,
Respectfully, I'd be Appeitant
Resphalt Park 1435947 McConnell Unit 300 South Eauley Drive 0541188 Texas, 75102
*9
*10 NES. 05-14-00877-CR, 05-14-00878-CR, 05-14-00879-CR, 05-14-00880 FILED IN COURT OF APPEALS
REGINALD HEITH PINK ARR. 1941 V.
STATE OF TEXAS APPELLEE
MAR 042015 USA MATZ CURRUY AND DISTRIPPEXAS FIFH DISTRICT
MOTION TO DISALISS APPELLATE CAINSEL AND APPELANT NEW COUNSEL
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NEW REGINALD KEITH PINK, ARR. 1941 AND RESPECT- ANY MOVES THAT THIS COURT DISALISS APPELIAUT CAINSEL MATHEW KITA AND APPELANT NEW COUNSEL PERSONNT TO THE Gt AND KtH. AMENDMENTS of the US. CONSTIUTION THAT CARTANTEE THE RIGHT TO COUNSEI AT EVERY CRITICAL STAGE OF MY DETENSE INCLUDING COMPETITION OF APPELLATES BRIEF. Also, PRESELANT TO TEXAS CODE OF CArMICAL PRODUCURES. Ann. Art. 1.051 WHICH ASSURES THE RIGHT TO REPRESENTATION OF CAINSEL FOR INDIENIT APPELLANTS.
I. APPELANT WILL SHOW THAT ON NOVEMBEE 5.000 MY CAINSEL ALED AN ANDERS BRIEF AND A MOTION TO WITHORAW AS MY CAINSEL. AT THAT TIME MY CAINSEL WAS FUITY AWARE OF A "LOST"OR"MISSIMET TRANSCRIPT AND THE FACT THAT I WAS IN POSSESSION OF EVIDENCE THAT PROVES A PERIOD OF THE
*11 COURTEEMERCERS RECORD WAS NOT INCLUDED IN THE AMESTATE RECOND THAT HE RECEIVED TO MAKE THE DETERMINATION (EN EARIR) THAT MY, WAS WITHOUT ANY MERIT. APREAL II.
APPEILANT COUNSEL PROVED HIMSELF to be INSELLICTIVE IN HIS ASISTRUCE AS MY COUNSE DY REVUSING TO DO APPREILATE FACT FINDING AND INVESTIGATION TO SEVURE ALL RECORDS AND EVIDENCE NEEDED TO MAKE AN ACCURATE DETERMINATION OF THE EJEANDS Are my APREAL. MY KITA REPUSED/DEFINED TO REAWEST OR MCTION THIS LOWER TO COMPET THE COURT REAVERY OF THE APPEIIATE RECORD AND PREFACE THE LOST TRANSCRIPTS! MY COUNISEL ALSO REPUSED TO MOTION THIS COURT TO MANIDATE I EEE BENING EMPRENTEO DARK TO DALLAS COUNTY TO TESTING TO WHAT HAPPENED AT THE HEARING IN JANUERARY THAT WAS NOT MADE PART OF THE APPEINTE RECORD. (SEE EXHIBIT (E)) THIS AFTER THE TRIAL COURT EENED THE SAME REAWEST. (SEE EXHIBIT(A)) III.
APPELANT WILL AED SHOUL THAT, ONWHTHEE REAWEST WERE MADE BY THE APPELHANT Are MY COUNISEL TO PIIE MOTIONS FOR "LOST," C.R.R AND BENCH WAKEANT TO SHOW WHAT HAPPENED DURING "LOST" HEARING CVO MY COUNISEL PIIE AN AVEERS ERIER (SEE EXHIBITS (A)) II.
APPEILANT COUNISEL WAS ALSO MADE AWARE THAT SEVERAL LAVCONISTITUTIONAL VEOLATIONS HAD ACCURED DURING THE HEARING THAT WAS NOT MADE PART OF THE RECORD AND THAT THE HEARING CECURED IN JANUERARY 2014. ELEAN THOUGH THE COURT REPORTER, WA E-MALL HAD DEVIED ANY HEARING CECURED OR ALERE HELD ELKING THE DATES OF FIT-N THEU FIT-N, MY COUNSEL WAS ASKED BY ME TO DEKWEST"DOCKET SHEETS" AND "EANLY DOKKET SHEETS" AND DALLAS CUNNYY JUDICIAL SYSTEM DICKET SHEETS," TO POWVE A HEARING WAS HELD AND WHEN, MY COUNSEL STILL HIEED THE ANDERS ERIER IN ERROR(SEE EXHIBIT (A)) I.
THE APPEILANT PRAUS THAT THIS COURT WILL AENEEE THAT BECAHSE APPEILANT COUNISELS' DETERMINATION THAT A ANIERS PAWES WAS WARMANTEO WAS BASED WHOLEY ON AN IACOMOLETE APPELLATE RECORD(SEE ATACHED MOTION TO WITHORAW ANDERS ERIER), THAT THE APPEILANT COUNSEL MR. KITAS' MOTION TO
*12
WITTERAN SHOULD BE CRAINTED AND I BE APROINTED NEG CONNAEL, GRAUSE THIS ANIERS DRIE? Is DOTH FERMALEY AND SUBSTANTILEY DEPECTIVE ACCORDING TO TRVAS RULE OF APPELATE TRACEDURE 38.9 (a)(b), GRAUSE, A PORTION OF THE APPELATE TROORD is "LOST" AND NOT CONSIDERED WHEN ANIERS DRIE? WAS FIRD, ALSO, APPELANT PRAYS THAT SOME SPECIAL CONSIDERATION BY THIS COURT BE CHING, THAT I MAY BE APPELNTED NEG CONNAEL SPECIFICALLY FROM THE PUBLIC DEPENDERS OFTCE LAY THIS COURTS MANDATE, AND NOT APPEINTED AN OUTSIDE ANIERNEY BY THE COURT.
REPRESYEEN SHRNTTED IEd F. 16 APPELANT RESHOULD RAR 1938997 MEDONHEH ONT 3001 SMITH EMILY DEVE IEEEVE TEX 78102
CERTIFICATE OF SERVICE
I HEREBVEETTAY THAT ON FEDURARY 27.2014, A TPIE AND CORRECT COPY OF APPELLANTS'MOTION TO DISMUSS CONNAEL AND APRINT NEN CONNAEL WAS MATIED TO THE ANIERNEY FOR THE STATE, BY FIRST CLASS MAIL ADVERESED TO:
MICHAEL R. CASILLAS DALASCAWITY DISTRET ATORNEYS' OPPER 133 N. RIVERFRONT BENLEVARD, LIB 19 DALAS. TEXAS 75887
*13 Nos. 05-14-00 878-CR, 05-14-00 878-CR, 05-14-00 879-CR, 05-14-00 880-CR.
REGINALD KEITH PINK Morthemt V STATE OF TEXAS Appellee
8 Courter of Aperals of Texas Fiftal Distriet
EXHIBITS IN SUPERAT OF MOTION TO WITH DRAW ANDERS BRIEF, AND MOTION TO BE APPOINTED NEW CAWEE
EXHIBITS OF FACT
EXHIBIT (A) LETER DATED OCTOBER 10,2014, Page 2 of 2 HIGH LIGHTED EXHIBIT (B) C.R.R. FEBURARY 3,2014, Vol. 2 of 4, Page 30 LINES 1-12 HIGH LIGHTED EXHIBIT(C) C.R.R. FEBURARY 3,2014, Vol 2 of 4 page 31 LINES 22-25 AND page 32 LINES 1-4 HIGH LIGHTED EXHIBIT(D) C.R.R. FEBURARY 3,2014, Vol. 2 of 4 pages 35 LINES 6-12 HIGH LIGHTED EXHIBIT (E) C.R.R. FEBURARY 3,2014, Vol. 2 of 4 pages 35 LINES 6-11
EXHIBIT(F) LETER FROM CAWEEI DATED NOW. 1,2014 page 2 of 3 HIGH LIGHTED EXHIBIT (G) LETER FROM ME TO MY CAWNEI DATED 10/23/14 Ages 1 of 2 and 2 of 2 HIGH LIGHTED EXHIBIT (H) E-MAIL DATED 10/20/14 FROM CAWET REPORTER EXHIBIT (I) LETER DATED 11/21/14 REAWESTING DICKET SHEETS/DEC. EXHIBIT (J) LETER DATED 11/21/14 REAWESTING DICKET SHEETS/DEC.
*14
LA LETTER HEIS picking his wortle
A.
Dear Mr. Pink: Today, I received your letter dated October 6, 2014. I would like to provide you with a update on your case and respond briefly to three of your requests. I am not lexpond to the my. repand I wailed to, comein
*15
*16 Reginald Keith Pink (No. 01938997) William G. McConnell Unit 3001 South Emily Drive Beeville, Texas 78102
Re: State v. Pink Trial Court Cause Nos.: F0955346, F1360732, F1360733, and F1372123 Pink v. State Dallas Court of Appeals Case Nos.: 05-14-00877-CR, 05-14-00878-CR, 05-14-00879-CR, and 05-14-00880-CR
Dear Mr. Pink:
I received your correspondence dated October 17, 2014 and October 23, 2014. Please accept my apologies for the delay in responding to you. I had a trial for one of my other clients in federal court on Monday through Wednesday of this week, and had spent the better part of the previous week preparing for it. As a result of this trial, I sought another extension from the Court of Appeals so that I could have some additional time to file a brief on your behalf.
Unfortunately, after a thorough review of the record in your case, as well as an exhaustive search of the applicable case law, it is my professional opinion that you do not have a good-faith basis for an appeal of your conviction and sentence. Accordingly, as required by state and federal law, I have filed a motion to withdraw as your counsel, as well as a brief in support of this motion, both of which are attached for your review.
In your letter dated October 17, 2014, you stated, "I have thoroughly and diligently researched this matter and I found no case law that can be used to get around a clear and unquestionable constitutional violation. Once your constitutional rights have been violated, they cannot be unviolated!" You also suggested that the trial court's failure "to pass [you] to a different attorney" constitutes a due-process violation. With all due respect, these statements are simply not correct. As I mentioned to you in my letter dated September 5, 2014, even assuming that some evidence existed to suggest that your rights to due process and effective assistance of counsel were violated, such violations are not a basis for reversing a judgment against you unless you can also show that the court likely would have reached a different result if you had received proper counsel. This has been the well-established law from the Supreme Court of the United States for over thirty years. See Strickland v. Washington, 466 U.S. 668 (1984). Because on the record, you freely
*17 and voluntarily pleaded guilty, acknowledged that you had gone over all of the indictments with Mr. Lacy-as well as the state's motion to revoke your probation, and conceded that you were satisfied with Mr. Lacy's representation of you before you were sentenced, these claims necessarily fail.
- Accordingly, with regard to your requests that I (a) file a motion to "force" the court reporter to produce the record of a hearing; and (b) file a motion seeking a bench warrant so that you can "prove" the contents of an allegedly-missing record, I respectfully decline to do so. Based on your description of the contents of this alleged record, it is my professional opinion that they are irrelevant to any issue that could be raised on appeal.
Although I was hoping to find a case that would support my argument that you are entitled to a new sentence, my search came up bare. As discussed in the attached brief, not only has the Supreme Court of the United States explicitly affirmed the constitutionality of Texas's habitual offender statute, I was not able to find a single case from any jurisdiction in the United States-federal or state-to suggest that a life sentence for a defendant with numerous aggravated-robbery convictions violated the defendant's constitutional rights. And because you pleaded "guilty" to the alleged offenses and "true" to the prior convictions and probation violations, I cannot challenge the merits of the charges against you. Thus, there are no additional arguments that I can raise in this proceeding.
I realize that you likely disagree with me with regard to the law that governs this issue, and I do not wish to debate you on this topic. You should be receiving a letter from the court of appeals in the near future, which will inform you that you have a right to submit a response to my motion in the court of appeals on your own behalf, wherein you can apprise the court of the cases that you believe I have overlooked, and the evidence that you believe must be obtained in order to assert your arguments. Should you wish to file a brief before you receive such correspondence from the court of appeals, you should send it to the following address:
Ms. Lisa Matz
Fifth Court of Appeals
600 Commerce Street
Dallas, Texas 75202
Be sure to reference the case numbers listed above in any correspondence with the court. You already have a copy of your complete appellate record, which you should also reference in any brief that you may file. If the court agrees with me that there are no grounds on which to seek an appeal, my motion will be granted, and our attorney-client relationship will terminate.
Finally, you should know that the unavailability of a remedy by appeal does not necessarily foreclose a court from considering whether your constitutional rights were
*18 violated. I have enclosed an annotated copy of Chapter 11 of the Texas Code of Criminal Procedure, which explains how you can petition the district court for a writ of habeas corpus. In the petition, you can ask the court to consider additional evidence that does not appear in the record. You should know, however, that you cannot pursue a writ of habeas corpus until your appeal is final. Also, I cannot file such a petition for you, as it is outside the scope of my representation, and beyond the boundaries of my expertise.
I understand that this news is likely to be disappointing to you. But because the court of appeals cannot consider arguments that are not grounded in the record as it currently exists, I firmly believe that my duties and obligations as an officer of the court do not permit me to raise the arguments or file the motions that you are requesting.
I wish you the best of luck and success.
*19
Page
(a)
I just received your letter dated 10/20/11. So, with all due respect let and be absolutely straight with you. Between Jan 18 and Jan 27th there was a hearing and it was on the record. My records of the three I went to cruel indicate 117, 128 and 1-27 and I spoke to me every on 17 -19 via veral computer. When he informed me he was scheduling a hearing out the finds (happens) to have the jodg's name me plan. He did and we had aheass on the record (I have a search record) The hearing was scheduled by Mr. Lkey he- cause I would not plan up being able to sa mid go over public reports to charge you know you a. I just that you hearing is held to get a person to give a plan on charges as serious as some, the hearing would be recorded as a rule of, though to have a record (foward) And it was recorded on the record but I would not give a plan that they and it was is scheduled per request of Mr. Lkey. It was must be 1-27 (Judge was leaving empty) meant to be 3,200 - 3 to pouse it, I am requesting you please, I just check with the bolly (this records) and clust the other text. 'Note Jan 1-27 give me being scheduled for a hearing: then, would you please check 'count check (councer) records for hearing if Jan 1-27. I'm saying Between the 12 + 27th because I know these are only (1) knowing in any case that it actually succeed any or some sritated word and not have the hearing. We de- solutely did have (1) having in I'm saying of this year. Again Mr. Kita I D2. HMy ASSURE Most, driving was held and was done so on the record do the roon contents will place in being the truth and you same, because this record has miyationally disexpeared? I don't think so! With all this being said on this, I'm requesting you as my atticary to spline this (as you as records) a written in this proper motion with the count of oxygen. I'm ready to the trial room (reportion) to know every incomplete portion of a product record for the hearing that was held or recorded in
*20 Pg. 2 of 2
January Between the 8 and the 27th for certain! And please ask the Coast of Appeale to attack strict time requirements to this request because there has already been given, ample opportunity to turn over this record to the coast of Appeale and you and I. Now, in the case that the coast reporter ste must that there is not a record of A reening in Jan 1900. If 27th, I am requesting you as my appointment at January to rule a motion with the Coast of Appeale to have me some investment. I don't to Dulless County in that I am good! "but just costly) but so pray to you and the coast of Appeale (undisputable proof) that a hearing was held and was held on the record! I do not understand why Indae Masnu would not touch account me back, because he was present at the hearing the same news!
Above, not by me as soon as you have filled and the report has ruled on these motions and keep me updated on everything. I appreciate you help I youcoughing with me in a timely manner to this point Mr. Kita. I appreciate you helping me locate this cavity important record to my appeale your service help overall. I would again take to you to keep this letter I all our correspondence as part of my permanent file as I am keeping a celdon reply for my personal records. One best time Mr. Kita, I'd like to seenserates I have read the most! This hearing was held and recorded! On January 1st, 30th, 37th
The last question, in the email you received from the coast reporter, is she saying, there is no period, or that she cannot yield the record over one depending from the 835 in the meantime. I'm reviewing what class records I appointed records and preparing to what any and all persons who may like to help me find this record that is used to any appeal. That you open and I look forward to having given you our soon Pg. 1 of 1
I might this, as mean as recaloud I say
*21
Subject: Re: State v. Reginald Pink (F-09-55346, F-13-60732, F-13-60733, F-13-72123) Date: Monday, October 20, 2014 at 9:13:21 AM Central Daylight Time From: Bridget Barnhill bridget.barnhill@yahoo.com To: Matt Kita matt@mattkita.com no hearings during that time
On Friday, October 10, 2014 1:40 PM, Matt Kita matt@mattkita.com wrote:
Ms. Barnhill,
My client has advised me that there was a hearing in this case sometime between January 17th and 27th that was on the record, but was not made a part of the reporter's record in this appeal. Can you review your files and confirm? Of course, if such a hearing was held, we would like to supplement the record in the court of appeals.
Thank you for your assistance, and have a good weekend. Matt Kita
Matthew J. Kita Attorney and Counselor at Law 214.699.1863 (phone) / 214.347.7221 (fax) matt@mattkita.com If you are not the intended recipient of this message, please delete it.
*22 STATE 180 1 Am. Count Ceark
Farm: Reginald Park Mr. Council Unit Sour Emily DovE Sourille 72.73102
RE: Teral Count. Coase Nos.: F0955346 F1360732 F1360733 F1372123 Dear Count Ceark,
My name is Reginald Park. I am the department on the abuse cause numbered cases. I am herbesting that you abuse found to me as soon as possible the closest sheets for each cause number listed above, for the dates, from 7, 1904. 1905. 1906. 1907. 1908. 1909. 1910. 1911. 1912. 1913. 1914. 1915. 1916. 1917. 1918. 1919. 1920. 1921. 1922. 1923. 1924. 1925. 1926. 1927. 1928. 1929. 1930. 1931. 1932. 1933. 1934. 1935. 1936. 1937. 1938. 1939. 1940. 1941. 1942. 1943. 1944. 1945. 1946. 1947. 1948. 1949. 1950. 1951. 1952. 1953. 1954. 1955. 1956. 1957. 1958. 1959. 1960. 1961. 1962. 1963. 1964. 1965. 1966. 1967. 1968. 1969. 1970. 1971. 1972. 1973. 1974. 1975. 1976. 1977. 1978. 1979. 1980. 1981. 1982. 1983. 1984. 1985. 1986. 1987. 1988. 1989. 1990. 1991. 1992. 1993. 1994. 1995. 1996. 1997. 1998. 1999. 2000. 2001. 2002. 2003. 2004. 2005. 2006. 2007. 2008. 2009. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 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2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2037. 2038. 2039. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2061. 2062. 2063. 2064. 2065. 2066. 2067. 2068. 2069. 2070. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2078. 2079. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2011. 2012. 2013. 2014. 2015. 2016. 2017. 2018. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2027. 2028. 2029. 2030. 2031. 2032. 2033. 2034. 2035. 2036. 2040. 2041. 2042. 2043. 2044. 2045. 2046. 2047. 2048. 2049. 2050. 2051. 2052. 2053. 2054. 2055. 2056. 2057. 2058. 2059. 2060. 2071. 2072. 2073. 2074. 2075. 2076. 2077. 2080. 2081. 2082. 2083. 2084. 2085. 2086. 2087. 2088. 2089. 2090. 2091. 2092. 2093. 2094. 2095. 2096. 2097. 2098. 2099. 2099. 2010. 2011. 2012. 2020. 2021. 2022. 2023. 2024. 2025. 2026. 2030. 2041. 2042. 2043. 2044. 2045. 2046. 2048. 2050. 2051. 2052. 2054. 2055. 2056. 2058. 2060. 2071. 2072. 2073. 2080. 2082. 2084. 2085. 2090. 2091. 2092. 2094. 2095. 2096. 2097. 2098. 2099. 2010. 2020. 2021. 2022. 2030. 2041. 2042. 2043. 2052. 2054. 2056. 2072. 2074. 2080. 2092. 2094. 2096. 2098. 2099. 2099. 2010. 2021. 2022. 2041. 2042. 2054. 2056. 2074. 2098. 2099. 2092. 2042. 2044. 2056. 2072. 2094. 2046. 2054. 2060. 2074. 2080. 2094. 2096. 2042. 2072. 2094. 2098. 2094. 2042. 2044. 2056. 2074. 2094. 2046. 2048. 2042. 2072. 2044. 2072. 2044. 2074. 2042. 2074. 2044. 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*23 LA. ELLIAIT (5) (6)
Frem. Regurald link *1438771 mecinnell unit 3001 South Eanicy Drive Beeville IN. 73102 MTA. County Dist. Week 1/7/14 Caymunac Division
RE: TRINC CHUSE NOS: FO955346 F1360732 F1360733 F1372123
Dear Distinct Cbenk,
My name is Regurald Park. I am the dependant on the above cause mumbered cases. I am reguelling that you please foward to me, as soon as possible the DCNET STREETS for each cause mumber listed above, for the dates of, Jan. 7, 2014 thru Jan 27, 2014. Please foward these DCNET STREETS to me at the setusn address on this envelope and at the top of this letter. Thank you in advance for your reppriation and help in this matter. I sent youand to secciving this repprovalence from you in the very near future. It is very important that I breeve these DCNET STREETS for these dates and cause numbers as quictely as you can send them to me. I am entitled to these siccords by federal can
Thank you. CC: To my pasonal file. Reged RAE
*24 Ms Lisa Maze Clerk of the 6th Court of Appeals GW Commerce Street, Suite 200 Dallas Texas, 75202
Re: Court of Abveals Number: 05-M-00577-CR, 05-M-00878-CR 05-14-00 879-CR, 05-M-00880-CR Trial Court Number: F-09-55346, F-13-48732, F-13-40733, F-13-72123
Dear MADAM, As this court is obviously aware, on February 4,2015, I was denied the opportunity to have a second extension of time to secure pocket sheets and other postivest evidence needed to the present, to this court with my ad se response to the Anders Brief filed by my counsel Mantew Eitu.
Accordingly, at this time I am respecting, respectively, that this court give very strong consideration to the attack motion to withdraw anders brief and complete APPELATE Brief and the motion to discuss appellant counsel Mantew Eitu and the APPELATED New Counsel. Also I request this court consider the attack being effective in support of matters.
I thank you for your attestation in this matter. WANED you please file this REAWEST AND PAYING IT TO THE ATTENTION of the court as soon as possible for review and consideration
Thank you for your consideration,
Reportfully, Engel Fd. Appeleant
Reynard Pink APR36997 McConnell Unit 305 South Eaily Drive BEEFille Texas 78102
*25 Nos. 05-14-06877-CR, 05-14-06878-CR, 05-14-06979-CR, 05-14-06980-CR
REFINALD REITH PINK, 8
APPELHAM
V.
STATE OF PENZERS
APPELHEE
CULT. OF APPRALS TERMS FIFTH DISTRICT
MOTION TO WITHDRAW ANDERS BRIEF And SUOMIT APPELHCE BRIEF.
TO THE HONDRAble SUSTICES of THE COURT OF APPEALS:
CMEES NOW REFINALD REITH PINK, APPELHANT AND RESPETTED BY MY COUNSEI ON NOVEMBER 5,2014 AND THAT I BE AUDWED TO SUBMIT BIBEINATE BRIEF. I NEVER ASKED AR CONSENTED TO MY COUNSEI MATTHEW KITA' Filling ANDERS BRIEF. NOV DID HE AND I EVER HAVE ANY DISCUSSION AGAUT AN ANDERS BRIEF BEINCE AHEAD ON MY DEHACF. APPELHANT WILL EHOW that NOT ON!Y DID I NOT AGREE TO THIS ANDERS BRIEF, IT WMS ALSO Filed WITH ONLY PART of the COMPLETE APPELHATE RECORD BEINA TAKEN/ANGER CONSIDERATION, THERE IS A LAST. REPIION of the COURT REPORTERS RECORD THAT WAS NOT CON- SIDERED BY MY COUNSEI. A DIRECT VIOLATION OF VERNONS. TX. RULES OF APPELHATE, PROCEDURE RULE 346 (BYFIDACORDING LY, THE ANDERS BRIEF Filed BY MY COUNSEI ACCORDING TO (TRAP RULE 38.9) IS SUBSTANTIWES DETECTED.
I. APPELHANT WILL EHOW THAT MY COUNSEI WAS MADE AWARE OF THE'LLET' TRAILCRIPT AS EARLY AS OCTOBER 23,2014 (SEE BHIISIT(22)).INITALLY MY COUNSEI DID RECONEST THE COURT
*26 REPORTER TO SUPPLEMENTHE APPEIATE RECORD. SHE DEVIED THEREWERE ANY HEARINGS DURING THE TIME FROM 1-17-14-1-27-44 WHEN I WAS CALLED TO COURT FOR AN ARRIGAMENT HEARING(SEE EXHIBITIN) AT THAT HEARING SEVERA L. CONSTITUTIONAL HORIZONTONS DEVIERES WHICH I ALSO MADE MY COUNSET ALMEE. of, AT THAT POINT HE CONTACTED THE COURT AND REVISESTED I BE AVOULED TO SEE BEACH WARRANTED BACK TO DALLAS CHUNTY TO TESTIY AT A HEARING AS TO WHAT HAPPENED AT THE HEARING IF INDEEAT THE TRANS- CAIOT IS LOST THE COURT DEVIED THAT RECUEET: (SEE EXHIBIT (A)) AND
AFRICIANT will SNow PROOF FROM YHE APPEIIATE RECORD THAT A HEARING ZID DILUR IN JANUARARY AND IT WAS HELD ON THE RECORD. DURING THE HEARING ON FEEL 3, DUNY. THERE WAS ONLY ONE OTHER HEARING HEID IN JANUARARY. ON THE SID OF REAWAY FEBURARY THE THIR COURT THOKE, MACHUS MALES COMMERTS TO THE ABOUT THE PRIVIR HEARING IN JANUARARY WHERE I DID NOTICINE A PEAR ANDST WAS RESCHEDULED. HIS COMMENTS WHERE EJECIFEALEY ABOUT WHAT WE DISCUSSED IN JAN. HEARING (SEE EXHIBIT (B)) AED, I ADDRESS THE COURT SPERIFICALLY. ABOUT WHAT MY STORNEY SAID IN JAN. HEARING (SEE EXHIBIT (C)) AED, IN SAME FEEL HEARING, THE DISTRICT ATTORNEY AMMESSES THE COURT ABOUT WHAT SPECIFEAIN, HE HAD TOLD ME IN HEARING IN JANUARARY (SEE EXHIBIT (D) AND THAT HE SAID IT ON THE RECORD! AND LASITY, MOREN I ADDRESS THE COURT SPECIFICALLY ABOUT WHAT HE TOLD ME IN PRIVIR HEARING IN JANUARARY (SEE EXHIBIT (E)). THESE 4 STATEMENTS MADE WIRKERS, ME, JUDGE MAKING, DISTRICT ATOPOLEY PRIVIR AND MYSELF. ABOUT PRIVE THERWAS A HEARING. YEID IN JANUARARY AND IT WAS HELD ON THE RECORD!
III IN A LEVER TATED W/AS/IN I REAWESTED MY COUNSET MOTION THE APPEND COURT TO COMPET THE COURT REPORTER TO THEN ON THE "LOST" TRANCRITT AND ASK THIS COURT TO MAKIDATE I BE EEEYH WARRANTED BACK TO TESTIY WHAT HAPPENED IN JANUARARY HEARING AND I AERED MY COUNSET TO EET FOR PROOF THE COURT EACKEY SHEETS AND THE BACPA DICKET SHEETS TO PROCE THE ELECT DATE IN JANUARARY THE HEARING WAS HERC AT THAT POINT ME COUNSET FIIED at AMPERS BICET T MOTION TO WITTIDRAW AS MY COUNSET Y REVISED TO FIC ANY OF AEE MOTIONS I REAWESTED: (SEE EXHIBIT (E)) AND EXHIBIT (E))
*27
II. Accordimbly, the APPELlANT with ABSolute ceEfANty in His PERSONAL RECORDS AND His CLEAR MEMORY OF the FIRST AND ONLY ARRIGNMENT HEARING, HELD IN JANUERARY SETWEEY!-IT! AND I-27-14 WAS HEID ON THE RECORD. EVEN If tLE DATES ARE A DIFFERENT DAY IN JANUERARY, THE RECORD OF TME HEARING, iov APPELlATE RULE HAS TO CE MADE A PART OF THE APPELlATE RECORD. IT NOT, IT HAS TO CE CONSIDERED"LOST"OR WISKING, I THERE tERE, THE APPELlANT HAS MADE DRISENT EFFORT TO SECURE THE LOST TRANSCRIPT OR THE DALLAS COUNITY, JUdical SUSTEM (EIETRONIC) DICERT SHEETS (SEE ENIGITS (3)) THESE EFFORTS HAVE BEEN MET WITH LIMITED COOPEE FATION FROM THE COURT REPERTER, THE TRIAL COURT, COURT CIERE, AND THE DISTRICC CIERU. THE APPELLANTS EFFORTS HAVE BEEN ATADE IN WRITTME, AND WITH THE HEIP OF VARIOUS TANILY, MEADDERS IN PERSON AT COURTHOUSE facilities IN DALLAS COUNTY.
.
APPEIIANT PRAYS THAT THIS COURT CIRANT HIS MOTION TO WOTADRAW ANDERS BRIEF AND SUgMII APPEIIATES' BRIEF. Also, APPELANT PRAYS THAT THIS COURT ACREE THAT MY COUNSEL ETTDIED IN-FIAN, ANDERS BRIEF WITHOUT REVIEWING AND CONSIDERING CONTENTS OF LOST/WISSING, TRANSCRIPTS THAT WERE NOT MADE A PART OF THE APPEIIATE, RECORD. ECT, THAT HE WAS WITHOUT A DOLLST MADE AWARE OF, APPEIIANT PLATtER PRAYS THAT THIS COURT GIVE. SPECIAL CONSIDERATION TO MANDATING, I BE BEVEH WHEREOTED EACLE TO DALLAS COURTY TO TESTIY IS THIS COURT AS TO EXACTY WHAT VIOLATION OCCURED THAT ARE THAT ARE THE CHRONICOPE MY DIRECT ADEEAL, AND THAT THIS COURT ALSO GIVE VERY SPECIAL CONSIDERATION TO MANUATE THE COURT (TRAA) AND/OR CITICERS OF THAT COURT TO SUCHMIT DALLAS COURTY JUDICIAL SYSTEM DICKET THAT IS E ETEONICALLY STORED AND CONTAINS ALL COURT APPEARENES FROM MREIGNMENT TO SEVEREICING, THIS, TO ERING TO RECORD (APPEIIATE), All REEVERY REEVERY LOST" OR CONTITED TRANSCREETS OF COURT REPORTERS RECORDS THAT EN RULE HAVE TO CECONSIDERD BEFORE ANY BRIEF IS SUBMITED TO THIS COURT.
RESECTfully Submitted Rial 11/8 APPEIIANT RECIPALD THK 193957 MECONNEEY WHIT 3001 SULTH EARLY DIIIC BEEVILL T. T8102
*28
CERTIFICATE OF SERVICE
I HERRERY CEEPTLY THAT ON FEGURARY 27, 2014, A TRUE AND CURRECT COPY OF APREIMANTS MOTION TO HISTADRANI ANDERS AND SUBMIT APREICATE DRIEF WAS MAIED TO THE AVERNEY FOR THE STATE BY FIRST CIASS MAill AGERRESSED TO:
MICHEAL R. CASILIAS DALLAS COURTY DISTRICT ATCRONEY'S OTHRE 133 N. RIVERTRON BouteVARD, LB 19 DALLAS TR. 75207
A. Del Rt
REFINAD R. PINK
*29 NUS 05-14-00877-CR, 05-14-00878-CR 05-14-00879-CR, 05-14-00880-CR COURT OF APPERALS MAR 182015 CICERL USA MATZ DISTRICT Reviatad Keth Park, AWENTANT V. STATE OF TERAS, MAKELLEE
CALACT OF ARRONS of RAAS FIRTH DISTRICT
REGONAD KETH PARK's MOTION REGUSTING HEARING ON ISSUE of LOST TRANSCRIOT
TO THE MONDRAble Tustices of the CALet of APPERALS: COMES MAW REGINAD KEETH PARK, AMEMANT AND RESPOT Fully MOVES THE CALet TO ORDER HEARING ON LOST TRANSCRITT ISSUE.
I. EOTN THE, CALET REPORTER AND THE TREN. CALET HAVE BEEN AURVE AWARE OF THE ISSUE OF LOST TRANSCRIOT SINEE DISTORE DONE. AND HAVE TREN EVER THE OPERATUNITY TO AURRESS THIS ISSUE. THE TRIAL CALET REPUCED TO AIOU A PEARING AND THE CALET REPR- TER DENLED THE MISSING OR LOST TRANSCRIOT EXIST AND ANGUERED NO PEARING WERE HELD DUEINED THE TIME OF PEARING THAT OCCURED IN TRANURARY 24 HET BEYWEEN 1-7-14 AND 1-27-14.
II. APPEIANT HAS PREVIOUSLY SUBADIED TETTUS COURT, FROM THE APPERATE RECORD STATEMENTS MADE OY THE APPERANT, THE GUIDE OF THE TRIAL CAURT, AND THE DISTRICT ATTRENCEY THAT
*30 Please. Where was a neARink Held dueINt YHESSE DATES AND IT WAS Held outre BECORE. YHELOT TRANSCRIPTS ONTREN EHEREE NEEDED TO ASSER GROUNDS Are my AppenL.
II.
APPEIIANT CAN SHOW THAT DILIIENT EFFORT HAS BEEN MAIE ON MY PART TO SECURE ENCLAS COUNIY CROICIIN. SUPPEN DICRET SHETS" TO, PIOVE EORCT DATE OF ARRIGNMEAT PEARINt, THAT IS MISSING FROM THE COURT. REPORTERS RECORES, THESE EFFIRTS HAVE BEEN MADE IN WRITING ON APPEIIANT AND IN PERSON BY APPEIIANTS EARILY WITH NO EMEESS,
IV.
APPEIIANT CITENDS THAT WITH THE HEIP OF this COURTS ORDERING OF A PEARINE, ON THIS ISSUE AND THIS COURT IN MANPATING, DICRET SHEETS BE TURNED OUER TO THIS COURT AND TO APPEIIANT, THAT ISSUE CAN BE EASIY REDUCED.
V.
As I AM SURE THIS COURT WILK RURRE, THAT NO GRIEF SHOULD BE ACCEPTED AND SUBMITTED WITHOUT THIS COURT FIRST DEIERMINING, THAT APPEIIATE BECORD IS COMPIERE, WHICH IT IS NOT AT THIS TIME. THEREFORE,
VI.
ARRIGANT PEAYS THAT THIS COURT EFFANT THIS MOTION REPUESTING, HEEREND ON LOT TRANSCRIPTS, THAT HAVE BEEN ONTRED FROM THE APPEIIATEE BECORD. AND THRTHER THAT THIS COURT MANPARE DICLAS COUNITY JURIDIAL SYSTEM DICRET SHETT BE MADE AUGLABLE FOR CONSIGERATION ON THIS ISSUE,
DESTINUED E EARICE
LEETING THAT A COPY OF THIS WAS MADED IN THE U.S. MALEDON ON the MECLINICI UNIT, 3001 SALTH ENILY W. IN BEELITE N. 78102. ARIRESSED TO: COUNICT FOR APPEIIE MICHEAC CASIIIAS DAIIAS CA. DISTRICT ATORNEY ATTRE 133 A. EHERPEENT BOUIEUARD L6 19 DADAS TX. 75207
*31
Ms UsA MATE
Clear of the SH COURT of AMELLS LOD COMMEDUE STREET. SUITE 200 DALLAS TX. 75209
RE: COURT of AMELLS No: 05-14-00877-CR,05-14-00888-CR 05-14-00879-CR,05-14-00890-CR
DEME MADAM,
EN THIS LETTER I AM GIVING THIS COURT NOTICE THAT THERE IS AND HAS BEEN the same time A VERY SEALS ISQUE OF A "LOST TRANSCRIPT." ALSO, I WELLD LIKE TO CONVEY TO THIS COURT THAT THE AMELIARE BEVED THAT IS CURRENTly BEFORE THIS COURT IS INOMIDIETE AND WOID A PORTION OF THE COURT REPORTERS BEVED THAT IS NECESSARY THE ME TO ASSEET THE CIRCUDS OF MIV AMELAL.
I AM REOUESTING THAT THIS COURT ORGEE A RULING THE A A HEMERING TO AMELESS THIS ISQUE OF LOST TRANSCRIPT. PEASE THD ENOUSED, ANY MOTION REOUESTING HEMERING ON'LOST TRANSCRIPT. PEASE THE AND BEING TO THE ARENTION OF THE COURT.
THANK YOU FOR YOUR CONSIDERATION
*32
*33 Cour of AMEALS Nos. 05-14-00577-CR, 05-14-00878-CR 05-14-00879-28, 05-14-00880-CR
TRIAL COURS Nos. F-09-55346, F-13-60732 F-13-60733, F-13-72123
IN THE COURT of APPEALS AT DALIAS TEXAS FIFTH DISTRICT
RECLINALD REITH PINK APPELANT V. THE STATE OF TEXAS APPELMEE
MUTIAN FOR RECONSIDERATION of 2nd MUTIAN FOR EXTENSION of TIME TO FILE PRO SE RESPONCE TO ANDERS IREIEF
TO THE HENORABLE JUSTICES OF THE COURT OF APPEALS:
CANES AON REFINIRAD REITH PINK, APPELANT AND RESPECTFULLY MOVES THIS COURT TO RECONSIDER APPELINARS! 2nd EXTENSION of time REAWEST BY 30 DANS. IN SUPPORT APPELANT WILL SHOUL THE FILLUWING!
I.
ON FEBRIRARY 9TH I RECIENED NOTICE FROM THIS COURT THAT MY 2-4-15 REGWEST FOR TIME EXTENSION WAS DENIED. THIS WAS MY AND REWEST FOR TIME EETEN SIGN TO FILE PRO SE RESPONCE TO ANDERS BRIEF. I WAS WMRNED ON JANU PAPERY 5th THAT IF I DID NOT RESPOND BY 2-4-15 THAT MY APPEAL WELKD BE SUBMITED ON ANDERS BRIEF ABOVE.
II.
I AM RESPECTIULLY REWESTING. THIS COURT RECONSIDER MAY 2-3-15 MUTIAN FOR 2nd ATENSION OF TIME BECAUSE IT WAS MADE PRIOR TO THE 2-4-15 DEADLINE.
*34
Atticuan this court did issue warring, this court did not issue that I- 3-15 order with realidade myatast me asking for and extension, this court did not specific aly order I would not decide to ask for and extension of time to file the se bespone.
III.
An my 2-3-15 motion, I did convey to this court, leftament cause for an additional 30 DAY extension, and because of this courts break of my motion, 2-3-15, I have been resoluted and caused Harm by not being able to or when ed to a select ground that prove sufficient revenue to have been deftined to have received the same current demand super
*35 MS LISA MATZ C. 1 EEK OF the Sth COURT of APPEALS MARRU 17, 2015 600 COMMERCE STREET, SUITE 200 CHLLAS TX. 75202 RE: COURT of APPEALS Nos.: 05-14-00877-CR, 05-14-00875-CR 05-14-00879-CR, 05-14-00880-CR TRAU COURT CAUSE Nos.: F-09-55346, F-13-60782 F-13-60733, F-13-72123
DEAR MADAM, ON FEBURARY 9, 2015, I RECIEVED A LETTER DATED FEBURARY 4, 2015 FROM THE COURT of APPEALS NOTTEND THE THAT ANY FEBURARY 4, 2015 MOTION THE 2nd TIME EXTENSION WAS CENTED TO FILE A PRO SE RESPONSE. ANY TANUARRY 5, 2015 RESEVEST FOR TIME EXTENSION WAS CENTED AND THE COURT DYO WHEN THAT IF ANY RESPONSE WAS NOT RECIEVED IS 2-4-15, THAT APPEALS WEULO THE SUBMITTED ON ANDERS BEICF AIONE.
I AM DESPECTRally REOUESSING THAT THIS COURT RECONSIDER Mly FEBURARY 3, 2015 RESEVEST FOR 2nd EXTENSION OF TIME, RECEALSE IT WAS MADE PRIOR TO THE 24-15 DEADING, THIS COURT, ATTACKEDH IT DID ISSUE A WARNINGS, THIS COURT DID NOT SPECify THAT I WIXLD NOT BE ALLOWED TO REOUEVANVMORE TIME EXTENSIONS. IN MY 2-3-15 MOTION, I DID COURTLEY LEGITAMENT CAUSE FOR AN ADDITIONAL 30 DAY EXTENSION AND RECEALSE OF THIS COURTS' DEVIAL. I HAVE BEEN PRECUDICED AGAINST TALISING SEVERE HARM BY NOT RECISE ALLOWED TO ASSERI CIRCUADS THAT PRIVS SUBSTANTIAL DETECTS WITH ANDERS BRIEF. THIS CASE HAS NOT BEEN PROPERITY PRESENTED, EVIDENCE TO PROVE LOST TRANSCRIP (DECKET SHEETS) HAS NOT BEEN CONSIDERED BY THIS COURT RECEALSE I WAS NOT CENTED EXTRA TIME (2nd TIME EXTENSION) TO SECURE DECKET SHEETS TO PROVE THE APPELATE RECORD IS INCOMPLETE.
PRAUSE, TIND ENENSED MY MOTION FOR RECONSIDERATION OF 2nd MOTION FOR TIME EXTENSION. PRASE FIC AND BRAND TO THE ATTENTION OF THE COURT THANE YOU ARE YOUR CONSIDERATION, REVISED FOR MAY 1938 REVISED FOR MAY 1938 REVISED FOR MAY 1938
*36
*37 COURT of APPEALS Nos: 05-14-00877-CR, 05-14-00878-CR 05-14-00879-CR, 05-14-00880-CR
TRIAL CAUSE Nos: F-09-55344, F-13-60232 F-13-60733, F-13-73123
IN THE COURT of APPEALS AT DALLAS TEVAS FIFTH DISTRICT
RECHINALD REITH PINK APPELANT STATE OF TEXHS APPELREE
MOTION REWUESTING THIS COURT TO COMPEL THE TRIAL COURT, COURT CHEEK, CUSTODIAN TO PRODUCE THE DALLAS COUNTY CABICIAL SYSTEM DOCRET SHEEIS TO THIS COURT TO RESCUE ISsUE OF LOST TRANSCRIPTS
TO THE MONORAble Justices of the COURT of APPEALS: COMES NOW RECHINAD EETTH PINK. APPELLANT AND RESPECT TULLY THIS COURT CONSETER THE ABOVE STYLED MOTION. IN SUPPORT APPELANT WIL SHON THE POUGHIONS:
I. THE PRESENT ISSUE OF LOST TRANSCRIPTS HAS CAUSED EAPREN IOUS HARM ISY PROCEDUREALLY DE PAULTING EPRORS THAT THAT SHOULD BE RAISED ON DIRECT APPEAL. THIS CREATES LEGAC PRETUDICE APPECTING COMAERAL REVIEW OF THE PRESENT ISSUE SHOWING, EAPOR SUPPORT BY COURT TRANS CRIPT.
*38 IN.
DICKET, SHEETS WILSOND BY EIETRONIC PRINTOUT, AND
COURT, APPEARENCE FROM ARRIGAMMENT TO SENTRACING
IN.
I HAVE MADE DIIIGENT EYAPETS IN WRITING TO DISIRECT CHEM, TRIAL, COURT AND COURT CERE, REAWESTING EIETROVIC. ALLY STORED DICKET, SHEETS AND LOST TRANSCRIPTS ALSO, IN PERSON BY PERTIVES AND THESE RECORDS HAVE NOT BEEN THANED OVER!
IN.
ACUARDING TO THE EREN RECORDS ACT AND TEE TEXAS PUBLIC INFORMATION ACT, THESE RECORDS ARE AND SHOULD OR MADE AVAILABLE TO ME AND TO THE PUBLIC.
IN.
THERE IS AN UN RESCUED ISSUE OF LOST TRANSCRIPT PROTEINS PEDUEST of THIS COURT TO COMPEL DICKET SHEETS IS PESUURE. LY NECESSARY TO RESUUE THIS ISSUE, WITHOUT THESE RECORDS. THE AMEIRTE WILL REACH RECORD WILL REMAIN THROMBERE.
IN.
THIS COURT DICKS HAVE LEEVAL JURS DICTION TO SETTLE THIS ISSUE OF DICKET SHEETS AND LOST TRANSCRIPTS, AND APPEIMENT. PRANS THAT THIS COURT WILL GREATED THIS MOTION TO COMPEL EETROVICALLY STORED DICKET SHEETS, TO INSELRE THAT THIS COURT TAKES HUVER CONSIDERATION ALL THE FACTS RELATED TO THIS CASE PRIOR TO SUBMISSION, AT THIS POINT THE APPEIRTE RECORD IS INSEMBHERE OF AN REPORTERS RECORDS.
THANE YOU FOR YOUR CONSIDERATION.
EXPLAINS OF SERVICE
I HEREBY CERTIN THAT A REPVOY OF THIS MOTION WAS MIXED. IN THE U.S. MAZLACK OF THE MISCHAMEL HAIR 300 SALTA EACH DRIVE, BEEVILLE T 78022.
MARRISSED TO: CANOSEI FOR MARISEE MICHAESE CASILLAS.
DALLAS CA DIST AMOISEY OFFICE 133 N. RUEOTRONY DILLE, LA 19.
DALLAS TX 75207
*39 Ms. Lisa, MATE CERE of the 5th COURT of AFFEALS 600 COMMERCE STREET, SUITE 300 DALLAS TX, 25202
RE: COURT of AFFEALS Nos: 05-M-00877-CR, 05-M-00878-CR 05-M-00879-CR, 05-M-00880-CR
TRIAL COURT CAUSE Nos: F-09-55346, F-13-60732, F-13-60733, F-13-72123
DEAR MADAM, THE PRESENTISSUE OF A LOST TRANSCRIPT IS CANSING ENERGATIONS HARM BY PROCEDURALLY DEPAGUTING EFFORS THAT SHOULD BE RAISED ON DIRECT APPEAL, I AM REAWESTING THAT THIS COURT CONSIDER THE MOTION ATACHED TO THIS LETTER. EFFROUR "DOCKET SHEETS" AND LOST TRANSCRIPTS ARE PRESENTLY NOT BEING CONSIDERED BELAUSE THE APPEIATE RECORD IS INCOMPIEER IN ITS PRESENT FORM. DALLAS Co. INDICAL SYSTEM EFFRONICALLY STORED DICKET SHEETS WILL RESOLVE THIS ISSUE OF LOST TRANSCRIPTS AND THE EXACT DATE OF LOST TRANSCRIPTS.
I AM ASKING THIS COURTS HSSISTANCE IN SECURING EVIDENCE (DICKET SHEETS) TO PROVE ISSUE OF LOST TRALE CRIPTS. REEASE FIND EXCLOSED MY MOTION REAWESTING THIS COURT TO COMPEL THE TRIAL COURT, COURT CRAAL AND CUSIDDING TO PRODUCE DALLAS Co. INDICAL SYSTEM DICKET SHEETS TO THIS COURT TO RESOLVE ISSUE OF LOST TRANSCRIPTS.
REEASE, FIND MOTION EFFUSED, HIS AND BRING TO THE ATTENTION ON THIS COURT.
RECINACO RANK MACONICO LANT 300 SMUTH EMILY Dr. BEEUELLE TX 78109.
RESPETALLY DAR CA MAYEAN
*40
*41 Cuvars of Ameals Nos. 05-14-00877-CR, 05-14-00878-CR, 05-14-00879-CR, 05-14-00880-CR
IN THE COURT OF AMEALS AT DALLAS TX. FIFTH DISTRICT
REEVENHAD HEITH TINK AMELHANI THE STATE OF TEXAS AURELREE
MOTION TO TAKE NOTICE OF ISSUES OF LOST TANS-CRIPTS, NEED THE EXPERCIVILITY STORED DOTES SHEETS AND THEIR CAUSE AND VRETHDICE
TO THE HUNDRABLE CUSTICES OF THE COURT OF AMEALS: CONUS NEW REEVENHAD PENIM AND RESPETTED BY THIS COURT CONSCIDE THE ABOVE STOLED MOTION. IN SUPPART AMELHANI WILL SHOUL THE FONDULDING:
CASE AND PRETHDICE THE MESSENT ISSUE OF LOST COURT REPORTS BECOPPS AND EXPERCIVIL DICRET SHEETS WAS CAUSED EARREGIOUS HARM ON PROVIDUOALLY DETAWITING ERRORS THAT SMOULD BE RAISED ON DIRECT AMEAL, THIS CREPTS LEGAL PRETHDICE MIFECTING COMPREPALE REVIEW OF THE MESSENT ISSUES SHOULDING ERRORS SUPPARED BY COURT TRANSCRIPTS, PREE TENS- CREPTS HAVE REEW WITHINED ON TOTAL COURT AND MESSENT REPORTS BECO IS INCOMBINTE. THISY LITAMINIZING OF TANSCRIPT WAS CACUATED TO IQRNE BY ROYAL TO INSTINATE APPERL OF ERRORS CONTRODED IN THE RECORD HELM TRAIL ClyCHT PROCEDURES. THIS MA s CAUSED SUBSTANTIAL DETEITS WID DEVELOPED
ARRETAST PRAUS THIS COURT THE NOTICE AND DEVELOPING A RUING ON this MOTION so THAT THEIR ISSUES ARE THEN CANCER CONSIDERATION BYTHS COURT
THINK YOU TAK YOUR CONSIDERATION, DESPEEETHDY PREE TENS AMELHANI
LEATING OF SEALICE
I HENERY CERTIF that A LAM of this MOTION WAS SEAT BY us, MAYL. TO: CALA SETTUR THE APPELICE; EU MEXHAN CASLINS, DOTCT OF THE LYM. RUWERBONT TANL L8 19, DALLAS TV 75287
*42 AMRIC 3,2015
RECEIVED
Count of Appeals
APR 08,2015
Lisa Matz
Clerk, 5th District
RE: REGINALD KEITH PINK U STATE OF TERMS
TRIAL COURT NOS. E-D9-55346, F-13-60733
APREALS COURT NOS. 05-14-00877CE, 05-14-00878CE
O5-14-00879CE, 05-14-00890CE
COSERCION TO STATES RESPONSE TO APRELIANTS MOTEN
FOR HEARING ON ISSUE OF LOST TRANSCRISTS
DEAR MS Matz,
TODAN I RECEIVED A COPY OF THE STATES RESPONSE TO APRELIANTS' MOTION REAWESTING HEARING ON ISSUE OF LOST TRANSCRIPTS, I HAVE NOT RECIE VED A COPY OF THE APRELIANT CONUSEIS' RESPONSE AS OF TODAYS DATE. IN ANY REVIEW OF THE STATES RESPONSE, I HAVE NOTICED REPORT AT THE DESIGNING THAT THE STATE DID NOT RESPOND IN TIME TO THIS COURTS LETTER/REAWEST, GIVING HER TO DAYS TO RESPOND TO MY MOTION REAWESTING HEARING ON ISSUE OF LOST TRANSCRIPTS DATED MARCH 18, 2015. THE STATE RECIEVED THIS COURTS REAWEST ON MARCH 19, 2015 AND DID NOT RESPOND UNTIL MARCH 30, 2015. (11 DAYS)
MY RESPONSE TO THIS LETTER FROM THE STATE IS AS FOLIOUS. THIS RESPONSE IN THE STATE IS NOT ADAQUATE TO RESOUVE THE ISSUE OF LOST TRANCRIPTS, I STRONSIFY FEEL THAT THERE IS ONLY ONE OBVIOUS WAY TO SETTIE THIS IS SUE OF LOST TRANSCRIPTS AND THAT IS FOR THIS COURT TO ORDER AN EVIDENTIARY HEARING ON THIS ISSUE OF LOST TRANSCRIPTS GO BOTH SIDES HAVE AN OPPARTUNITY TO ADDRESS AND PRESENT EVIDENCE ON THIS ISSUE.
THE TRANSCRIPTS STATE ASSERTS THAT SHE REVIEWED THE TRIAL COURT DACKET SHEETS. AS I AM SURE THIS COURT IS AWARE, THE TRIAL COURT DACKET SHEET ARE HAND WRITEN NOTES
*43 Nerthen on a sHEET of PAPER THAT HAS TRIAL COURT DICKET WARM WRIHTEN AT THE TOP of IT AND HAVE LITTLE TO NO VITAL OR AGAQUATE EALVE ACTIVITY RECORDED ON IT I AM SURE THAT ANY COMPETENT CRIMINAL CAW PROFESSIONAL WOULD ACF REE THAT THE DALLAS COURTY JUDICIAL SYSTEM DICKET SHEETS ARE WHICH ARE EIETRONICALLY STORED ARE A COMPUTER CENEPAYED PRUITOUT OF RECORD OF ALL COURT APPARENCES FROM ARRICIN MENT TO SENTENICING FOR EVERY CAUSE NDS. TO MY EWONLEDG, NEITHER THE STATE ATORNEY NOIR THE TRIAL COURT HAVE RELLEWED THIS MORE RELIABLE AND ADVOLVATE. RECORD. It IS MY CONTENTION THAT THIS COURT SHOULD ATHANEOMNEI EITHER THE DALLAS CO. JUDICIAL SYSTEM DICKET SHEETS OR THE DALLAS CO. SAFRIIFF DICKET SHEETS TO BE USED AS EVIDENCE ON THIS LOST TRANS CRIAT ISSUE. MY EPDGAS TO SECURE THERE RECORDS ON MY OWN HAVE BEEN DEVIED AND ICONORED.
THIS COURT MUST TAKE NOTE THAT BOTH COMBENTS AND STATEMENTS MADE BY THE TRIAL COURT JUDICE, THE CHIEF PROBE. GUTOR AND MYSEIP ON THE RECORD DICKET OURING FECHURARY 3,900 GRARENGY SURWIS ABSOLUTE PROOF THAT I WAS PRESENT WITH THE TRIAL COURT JUDICE, AND THE CHIEF PROSECUTOR IN OWN COURT AT A HEARING PRIOR TO THE PEDUARY 3,900 HEHRENGY AND PROUES THAT THE HEARING WAS AELD ON THE RECORD ACCORDING TO THE CHIEF PROSECUTOR IN MY TRIAL COURT (SEE APPERATE RECORD ICR. R. - P. FEB 3, 2014, WOL. 2, PACE 30, UNES. C. 2, WOL. 2, PACE 31, UNES 22-26, AND WOL. 2 PACE 32, UNES 1-4, WOL. 2, PACE 34, UNES 10411, AND WOL. 2, PACE 3E UNES 6-12.)
PIERSE NOTE THAT MY APPERATE COUNSEL AMIITEN ICITA DID NOT DO AROMPIETE AN ADAQUATE INTESTIGATION ONTHE ISSUE OF LOST TRANSCRIAT. HECKIDE TO FILE AN ANDERS BEEYE CULLY AFTER I RESUSTED HE FILE A MOTION WITH THIS COURT TO RESCUE THIS SANE ISSUE OF LOST TRANSCRIATS. AND HE REPISED TO SECURE AND RELLEW DALLAS CO. SHERIFF DICKET SHEETS OR THE DALLAS CO. JUDICIAL SYSTEM DICKET SHEETS I AM STILL IN RECIEPT OF HIS CENTER OF REPLUSAL, PROVING HE UID NOT DO A THOROULIA INVESTIGATION ON MY BEHALE ON THIS ISSUE OF LOST TRANSCRIPTS.
THIS COURT SHOULD AIDO. NOTE THAT NO MATTER WHAT DAY THE HEARING DICILRED, IT WAS HEAR ON THE RECORD AND EY RULE OF THE TIE. RULES OF APPLICATE PROCEDURE, IT SHOULD SE MAID A PART OF THE APPLICATE RECORD IN THIS CASSE OR THE RECORD THIS COURT IS REVIEWING IS CONSIDERED
*44 DEPETILE AND INCOMPLETE IT IS IMPERATIVE THAT THIS COURT TAKE LATER CONSIDERATION, A COMBLETE APPELIARE RECORD.
ATTHIS ADINT IN MY APPERL, I AM NOT BEING ABOVED. MY RELAT TO AN APPEAL, ISENUSE OF THIS LOST IMISSING TRANSCRIPT ARE NOT SEEING MADE PART of the APPELIARE RECORD. THEREFORE, BASED ON THE COMMENTS AND STATEMENTS BY MUSCLE, THE TRIAL JUCEE AND THE CHILD PROE-CUTOR FORM MY TRIAL COURT. IT IS MY CONTENTION THAT THIS COURT SHOULD ORANT MY MARCH 18, 2015 MOTION TO TO RESOLVE THIS ISSUE OF LOST TRANSCRIPT WITH THE HELP OF THE DALIAS COURTY JUCECIAL SYSTEM DOCUET SHEETS AND THE DALIAS CO. SHERET DICKET SHEETS AND THE REVIEW AND CONSIDERATION OF THE ABOVE MENTIANED PURTIONS OF THE CHRIENT APPELIARE RECORD.
ACOORDINELY, APPELLANT WREES THAT BASED ON FACTS SUPPORTED BY THE CURRENT APPELIARE AND/OR. AND STATED IN THIS LATER AND VALIDATED BY THE DALIAS CO. JUCECIAL SYSTEM DICKET SHERET SHERET AND THE DALIAS CO SHERI'AT DICKET SHEETS, THAT THIS AONOPAOLE COURT GRANT APPELLANTS' MOTION FOR A HEARING ON THE ISSUE OF LOST TRANSCRIPTS TO RESOLVE THIS ISSUE AND ASSURE THAT THIS COURT IS TAKING LATER CONSIDERION THE COMPLETE RECORD PRIOR TO SUBMITING THIS APPEAL FOR REVIEW.
ACLAM, I SPONELY FEEL THAT THERE IS ONLY ONE ORNOUS WHY TO RESOLVE ISETIC THIS IMPORTANT ISSUE OF LOST TRANSCRIPTS AND THAT IS FOR THIS COURT TO ORDER AN EVIDENTIARY HEARING ON THE ISSUE OF LOST TRANSCRIPTS SO BOTH SIDES HAVE AN OPPORTUNITY TO ADDRESS/PRESENT EVIDENCE ON THIS ISSUE.
THANE YOU FOR YOUR CONSIDERATION IN THIS MATTER. BEARS FIVE THIS RESPONCE AND GRING IT TO THE ATTENTION OF THIS COURT IMMEDIATELY.
NOTE: CE. TO MY PERSONAL THE. PREE SELD COPY TO ALL PARTIES.
*45
*46 April 7, 2015 Courts of Ameenls Nbs: 05-14-0087700, 05-14-00878000 05-14-0087900000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
*47 II. EAK THOUGH APPELANT COURSE DID REPALEST COURT REPASTER SHOREMEAN THE RECORD WITH MISSING/LOST TRANSCAJPT AND SHE SHED NO PEARINOUS MAPPEAROCCURING THIS DATES AND THE TRIAL STORGE REPUSED TO CENCH WARMENT THE EOKE TO A PEARING AFTER CENCH/MEET ON APPELANT COURSEL, APPELANT COURSEL REPUSED TO ANTON THIS COURT TARA PEARING ON/LOST TRANSCAJPTS AND REPUSED TO PENEON DALIAS COURT SHERIFF DICKET SHERTS AND RUPISED TO REVIEN OR INVESTIGATE DALIAS COURT SHORIAL SHSTER EMPROARially SOMED AND PRINTED OUT DICKET SHERTS, THE BEST ANTIFORITY!
III. ALI AM SURE THIS COURT IS AWARE AND ALL CAVINUAL LAS PRESSEDMMS KNOWS, THAT THE TRIAL COURT DICKET SHERTS ARE ON/Y HAND WRITTEN MORE NCCASE FIRS, THEY DO NOT ACCURATELY, CONTOGETEY REVIENT EVERY COURT APPEARQUEE THOOR ARRIGNMEAN TO SENTEACIUA LIKE THE DALIAS CO. JUDICIAL SHSTER EVERYCORTEES SOMED, DICKET DOES, AS A RESULT THE TRIAL COURT DICKET SHERTS SHOULD NOT HAVE BEEN USED, ON THIS COURT OR ACCEPTED BY THIS COURT IS THE THE BEST RESOURCE TO RESOLVE THE ISSUCE OF LAS TRANSCAJPS, AND THE TRIAL COURT DICKET USED BY ON/ APPELANT COURSE/ASHIS RESOURCE DOES NOT EVERIDE UITAL AND ADASSUATE CAUSE ACTIVITY RECORDED IN IT.
III. THIS COURT MUST HAVE ASIE THAT BOTH COMPRENEE AND SHRENEN'S MALE ON THE TRIAL-CAURT THOSE AND CHIEF RESOLUTE AND ANVEST OUTHE RECORD (APPELIARE RECORD) DURING FED 3,204 (REAREGY) SHOULS ASSOLUTE PROOF THAT I WAS PRECAUT WITH THE TRIAL COURT THOSE, CHIEF RESOLUTE FOR IN OPEAL COURT AT A PEARING FEDER TO THE FED 3,205 (REAREGY) AND PROVES THAT THE REAREGY WAS FED OR THE RECORD ACCORDING TO THE CHIEF RESOLUTE OF IN MY TRIAL COURT, (SEE APPELIARE RECORD) ORR -7 FED 9,2014 VOL. 2 DANE 80 LINES 142, VOL. 2 DANE 31 LINES 23-25 AND VOL. 2 DANE 32 LINES 1-4 AND VOL. 2 DANE 34 LINES 80+11 AND VOL. 2 DANE 35 LINES 6-12.
IV. ACCORDINGING APPAMEANT HREES THAT THIS COURT, BASED ON FACTS SUPPARTED BY THE BOPERATE RECORD "ORR AND FACTS STATED IN THIS (ANTON), THIS COURT SHOULD EARNT APPELIAUTS MOTION AND AULI APPELIAUT AND ALL PARTIES TO THIS APPERL TO BRING ANY AND ALL" EUDENNE PERTINENT TO THIS APPERL, SO THAT THIS COURT WILL CE ASSURED THAT IT IS CONSIDERATION, A
*48 COMDIETE RECORD AND ALL SALES. THE APPELLANE FEELS STRONDIV THAT THERE IS ONLY ONE ORIGUS WAY TO RESOLVE /SETTLE THIS IMPORTANT ISSUE OF LESS TRANSCRIPTS, AND THAT IS FOR THIS COURT IS ORDER A EUIDENTIARY HEARING so THAT ALL PARTIES HAVE AN OPPORTUNITY TO TO ADDRESS AND PRESENT EUIDENCE ON THIS ISSUE, AND NOT THAT ONE SIDE ISEDUE PRESENTED.
THE APPEIIANT PRAVS THAT THIS COURT ORDER AN EUIDENTIARY HEARING AND COMPEL DALIAS CAWITY CHOICIAL SYSTEM EIETRANICALL SIDED DOTKET (SPEEIIICALLY) THAT GHOMA EVERY COURT APPELAKE FROM ABRENIMENT TO SEEPELCHING. ABO, APPEIIANT PRAVY'S THAT THIS COURT REVIEW AND CONSIDER PORTION OF CURRENT APPEIIATE RECORD/C.R.R. THAT PROVES PEIOR TO FED 3, 2014, THERE WAS A PERFING HEAT OUTTUE RECORD AND THE TRANS CRIPT OF THAT HEARING IS LESS /MISSIVE/FRON THE PRESENT APPEIIATE RECORD. ALSO THAT THIS COURT COMPET THE DACKAS CO. SHERIA' DOOMET SHERIS AS WELL TO PROVE ALSO THAT THERE IS A LESS TRANSCRIPT. AND THAT THIS COURT WILL NOT ONLY CONSIDER THE SUBSTANTIALLY LESS POCURATE AND INSECTICANT TRIAL COURT DICKET SHEET ONLY, OUT CONSIDERAL" DICKET SHERIS AVAILABLE TO THIS COURT WIDER ITS CURRENT TWALSיםICIION, SO THAT THIS COURT WILL BE ASSURED THAT IT IS PRAKING THE PROST INFORMED AND ACOURAT RELUNG ON THIS MOTION.
THIS COURT SHOULD NOT PURPOSELY RECISE TO CONSIDERAL" FACTS AND EMIDENCE AVAILABLE TO IT. EVERY IT' EUIDENCE AND FACTS SHOULD TO BE IN THE FAVOR OF THE APPEIIANT, ANAN, ANY AND EVERY COMPETENT CRUMWAL LAW MOTESIONAL RANGES THAT THE MOST ACOURATE AND COMPETE RECORD OF COURT APPEARERES ARE KEPT BY THE DALLAS CO. THOICIAL SYSTEM DICKET EIETRANICALLY AND THE DHL, CO. SHERIA DICKET AND THAT EUEUIDENCE FROM THE APPELATE RECORD IN THE APPEAL PROCESS IS THE DOWWANT AUTHORITY IN THE TMES CAURE CONSIDERATION AND RELIGUS.
THANK YOU TOR-VOLE CONSIDERATION. CERCULATE A SERVICE E EERRY THAT A COPY OF THIS MOTION WAS DICKEN IN THE US MALE OF THE MEASURED UNIT 3011 SACH EHILY DRIVE, BEHAVE TO 78102 Addreses To: Micheal Casillas, Amherley on? DALAS C. R. REY REVELENCE AND L. B. 19 3.
*49 AAU/ 7, 2015 Ms. Lisa MATE CiteR of the 5th Count of ARKALS LOD COAMERCE STREET, SUITE 200 DALLAS TX. 75202 RE: COURT of ARKALS NDS: 0544-00877-CR, 05-44-00878-CA, 0544-00844-CR, 05-44-00880-CR Teine COURT CAUSE NDS: F-09-56344, F-13-60732, F-13-60735, F-13-72123
DEAR MS. MATZ, ON TODAY I RECIEYED AN ORDER PAUM THIS COURT DATED MARCH, 31, 2015; DENYINGY MY MARCH 18,2015 MOTION ON ISSUE of LOST TENNCEIPTS, MY MARCH 28,2015 MOTION TO REHEAR FEES 4,2015 MOTION, AND MY MARCH 25,2015 MOTIONS TO TAKE NOTICE OF MISSING RECORDS AND MOMOTION TO COMPET PRODUCTION OF THE DICRET SHEETS.
MY RESPONSE TO THIS ORDER IS THAT THIS COURT EFFORED IN NOT CHICING APPEIANT AN OPERATIANITY TO RESULT WITH THE STATES' AND THE APPEIANT COUNSES' RESPONSES TO MY MARCH 18,2015 MOTION TOE MEARING ON ISSUE OF LOST TENNCEIPTS, AND AS OF this DATE, I CAME NOT VET RECIEYED A COPY OF APPEIANT COUNSES RESPONSE.
THIS COURT AND EFFORED IN NOT GRANTING MOTION TO COMPET THE THE PRODUCTION OF THE DALLAS CONVITY TUBEING SYSTEM DICRET SHEETS WHEN CONTAIN THE MUST ACCUBAITE RECORD OF EXPERIMENTEYSTY STOREN COURT APREADEUCESTYM ARRICNMENT TO SEVITERICIAL.
ALSO, THIS COURT EFFORED OY NOT TERING UNDER CONSIDERATION THE EVIDENCE IN THE APPEIATE RECORD STATEMENTS BY TRIAL TWOOD, STATE PROSOCUTOR AND MYSEY, THAT PROVE WITHOUT QUESTION THAT THERE WAS A HEARING HEID ON THE RECORD THAT HAS DIDT BEEN MADE PART OF THE APPEIAT RECORD(SEE APPEIATE RECORD IC.ER FEB. 3, 2014. WOL. 2 PACE 30 LIMES 1-12, WOL. 2 PACK 3 LIMES 32-35, AND WOL. 2 PACK 33 LIMES 1-4 AND WOL. 2 PACK 34 LIMES 10-14 AND VOL. 2 PACK 35 LIMES 6-12)
PIERCE REVIEL/ APPEIANTS ARRII 3,2015 DISTECTION TO APPEIANTS'STORES MOTION ON HEARING ON LOST TRENCEIPTS AND TAKE IT UNDER SERIOLS RESPONSE
RESPONSE
*50 CONSIDERATION. Also, PERISE REVIEW AND EARIAT APREIMNTS' ADOIH MOTION, REINVESTING THIS COURT EARIAT MOTION FOR EVIDENTIARY HEARING, TO RESOLVE ISSUE OF COST TRANSCRIAT IN SO, ADDLUNG APPERIANT AND AN PARTIES PRESENT EVIDENCE TO SUPPORT THEIR AReLHMENT AND WVESTIGATION RESULTS
THAWLE VEX FOR YOUN CONSIDERATION IN THIS MATTER. PLEASE FIR THIS RESPONCE AND ANTACKED MOTIONS AND GENO THEM TO YHE ATTENTION OF THIS COURT IMMEDIATED'S.
RECERSTALLY EXHIBITTE 2.
*51
*52 Ms Lisa MATE CERE of the COURT SIA COURT of APPEALS GOD COMMERCE STREET, SUITE 200 DALLAS TEXAS, 75202
RECEIVED Court of Appeals APR 162015 Lisa Matz Clerk, 5th District
RE: COURT of APPEALS N/A: 05-14-00877-CR, 05-14-00878-CR 05-14-00879-CR, 05-14-00880-CR TRIAL CAUSE NEMIDES: F:09-55346, F-13-60732, F-13-60733 F-13-72123
Dear Ms. Matz,
I AM WRITING THIS LETTER IN LOOD FAITH TO THIS MONOMABLE COURT DEDUESTING THAT ITS SUSTERES GIVE CONSIDERABLE ATENTION TO MY APPEL 7,2015 MOTION RE- CONSIDERABLE ATENTION TO MY APPEL 7,2015 MOTION RE- CONSIDERABLE ATENTION TO MY APPEL 7,2015 MOTION RE- CONSIDERABLE ATENTION TO MY APPEL 7,2015 MOTION RE- CONSIDERABLE ATENTION TO MY APPEL 7,2015 MOTION RE- CONSIDERABLE ATENTION TO MY APPEL 7,2015 MOTION DY BRANTING THIS MOTION, THIS COURT WOULD CARRANTEE ITS DECISION ORRUING ON THIS MOTION BE ASSEDING FOR ALL PARTIES INVOLVED. DEDAUSE IN AUGUSTUS AL EXIDENCE TO BE PRESENTED AND CONSIDERED, THIS COURT WILL LEALE NO FROM FOR ANY ERRORS, WIRKING ADLE DETERMINATIONS OR VIOIATIONS OF ANY PARTIE INVOVED CONSTITUTIONAL RECENTS.
RECORDING!Y, AS I AM EVER THIS COURT WILL AGARE, IN A SITUATION SACH AS THIS ISSUE OF LOST TRANSCRIPTS, INCOMPLETE APPELATE RECORDS AND DISACTREEMENTS ON WHEN AND IF HEARINGS) COURTED AND HAVE NOT BEENWARD PART OF THE APPELATE RECORD THAT THIS COURT USES TO DETERMINE ITS OPINION OF THIS APPEAL AT HAND, THAT EVIDENTIARY HEARING IS OBVIOUSLY THE BEST ANDMOST APPROPERATE SOLUTION FOR THIS COURT AT THIS TIME, AT THAT HEENY ALL FAITS WILL BE CONSIDEREDLLETH A EVIDENTIARY HEARING.
THANK YOU FOR YOUR CONSIDERATION ON THIS ISSUE, PEAE THE THIS LETTER/RECUEST AND BRING IT TO THE ATENTION OF THIS COURT IMMEDIATELY.
*53
*54
APRIL 30,205
COURT of APPEALS Nos: OS-14-00877-CR, OS-14-00875-CR OS-14-00879-CR, OS-14-00870-CR
TRIAL COURT CALSE NOS: F-09-55346, F-09-60732 F-13-66733, F13-72423
IN THE COURT of APPEALS AT DALLAS TX. FEETH DISTRICT
| | RECHINUD REETA FUNE | | | | :--: | :--: | :--: | :--: | | | ADDESTANT | | | | | STATE OF TEXAS | | | | | ADVERTIEC | | | | | | | |
MOTION REAWESTING REMEARING of MOTION REAWESTING "EVIDENTIARY HEARTING" ON THE ISSUE OF COST TRANSCREPTS AND DALLAS COUNITY TUDICIAL SYSTEM ERETENICALLY SERED AND PRINTED DOCKET SHEETS
TO THE HONXRABLE STATICES of THE COURT of APPEALS: EXPRES NOW BEESINALD KEITH FENK, APREIMNT AND RESPECTSALLY MOVES THAT THIS COURT CONSIDER THE ABOVE, STYLED MOTION IN SUPPORT APRELANT CHILD SHOUL THE FORMING:
I.
THAT THIS COURT BEASE REVIELY AND CONSIDER"AL"EVIDENCE AND POINTS OF FACT STATED AND CULTIVED IN APREIMANTS FIRST MOTION FOR EVIDENTIARY HEARTING ON TSSUS OF LOST TRANSCREPTS AND DALLAS JUDICIAL SYSTEM ERETENICALLY SERRED AND PRINTED DOCKET SHEETS
II. THERE IS CLEAR, CONVINCING AND OOVIOUSLY SUPPORT EVIDENCE IN THE 'APPEIYATE RECORD' THAT IS BEFORE THIS COURT (SEE APREIMETICAR-FEIS 3,204 USL 2 PAGE 30 LINES 1-12, WAL 2 PAGE 31 LINES 20-25, WOL. 2 PAGE 30 LINES 1-4, AND WOL 2 PAGE 34 LINES 10411 AND WOL. 2 PAGE 35 LINES 6-12.) THAT ENTIYTE APPELANT TO A "EVIDENTIARY HEARING"
III.
FEDEMAL COURTS HAVE RULED THAT APPELANT IS ENTITED TO FUN AND FAER'EVIDENTIARY HEARING" TO DEUBLOPE ALL FACTS (SEE HALL U. GUARTERMAN 543 F.3d. 365, 367-69 (54, Cir. 2008) AND THAT APPELANT IS ENTITLED TO FULL"EVIDENTIARY HEARING" BASED ON THE FACT THAT I HAVE REPEATEDIY ATTEMPTED TO OBTAIN COPY OF ARRIENMENT HEARING TRANSCREPTS THAT ARE ASLUMED LOSTOR MISSIONED. (SEE DALTON U. GATAGLIA 402 F.3d 729, 736 (THA Cir. 2005).
*55 IT. IT WONED DE FUNDAMENTALLY UNIFOR TO RESOLVE THE ISLLE OF LOST TRANSCRIPTS AND EXTENNIC DICKET SHEETS SOLLEY ON THE WORD OF APPRELANT COUNSEE LIVED HAS PREVIOUSLY FIIED AN ANDERS EVER THE COURT SHOULD NOT REW EXCLESIVEIY ON ADPRIANT COUNSEIS DECLARATION ALONE.
IT IS OBVIOUS THAT SUPPCIENT FACT FINDING HAS NOT BE DONE IN THIS CREE AND'ALL' EVIDENCE OF PROOF AND FECTS HAVE NOTBEEN DEVELOPED TO JUSTIH THIS COURIS DENIAC OF AN FLII EVIDENTIARY MEARING.
ARRELANT DRANTS, THAT THIS COURT BRANT HIS MOTION FOR A 'FLUY EVIDENTIARY MEARING' ON ISSUE OF LOST TRANSCRIPTS AND DALIAS COUNTY JUDICIAL SYSTEM EIETRONIC DOCKET SHEETS TO RESOLVE THIS ISSUE.
THANIK YOU FOR YOUR CONSIDERATION
CERTIFICATE OF SERVICE I HEREOY CERTIFY THAT A COPY OF THIS MOTION WAS PIACED IN THE MAIL OF MEASURED UNIT 3001 SUUTH EMILY DRIVE, REECIRE TO 75102 AddRESED TO! MICREAC CASIAAS. DRUAS COUNTY DISTEXT ATDANEY Office 133 N. RIVERFRONT BLUd. L8 19 DALIAS TX. 75207
*56 ANGL 30.2015 Ms Lisa Mary Creek of the star COWes of AAPEALS 600 COMMERCE STREET, SUITE 200 CALLAS TELMS 75202. QE: COURT of AAPEALS NDS: 05-14-00877 CR, 05-14-00878-CR, 05-14-00879-CR, 05-14-00880-CR tRML COURT CAUSE NDS: F-09-55346, F-13-80732, F-13-60733 Dear Ms, MRTZ, ON 4/28/15 I RealBVED THIS COURTS ORDER DEVING MY MOTION RENUESTING EVIDENTIARY HEARING ON THE ISSUE of LOST TRANSCRIBED AND CALLAS COURTU SHOICIAL SKETEUM EIETRANICALLY STORED AND PRINTED CVO DOCKET SHEETS. THIS MOTION WAS DATED APRIC 13, 2015. THIS COURTS ORDER IN RESPOND' TO THIS MOTION IS DATED APRIC 22 2015. IN THIS ORDER, THIS COURT MISTRRENILY ADDRESSES THIS MOT MOTION AS M'Y 2nd MOTION FOR HEARING ON A LOST DECORD AND FOR DICKET SHEETS. MY APRIC 13,2015 MOTION IS, MY FIRST AND ONLY MOTION TO THIS COURT REAWESTING (SPECIFICALLY) A HEARING EVIDENTIARY HEARING" ON LOST TRANS CAPTTS AND DICKET SHEETS. This COURTS APRIC 22, 2015 ORDER AND OTHER DREWIONS ORDER WHE PEEEN MADE WITHOUT EXPLANATION, REPASEN, OR RULE TO SUPP PREF YOUR DECISIONS NECESSARY FOR TWICHTE EHENT UNDEPSTAND- ING OF DENING AAPEIANT AN EVIDENTIARY HEARING AND FACT FINDING IT APPERAS TO BE APRARENT THAT THIS COURT IS DEHBERNTENT CAUSING APPETIANT HARM AND PREFINDRE OR REPEATED DERWYN MOTIONS NECESSARY TO MARE A DITMENT AND COMPLETE FACT FINDING OF UNRESOVED ISSUES THAT ARE PRESENTLY DETERE THIS COURT IN THIS CASE. THEREFORE, I AM REQUESTING THIS COURT GRENT AAPEIANT ATTACHED MOTION TO REVER MOTION DATED APEXE 13,2015 REAWEST ING "EVIDENTIARY HEARING" ON THE ISSUE OF LOST TRANSCEIPTS AND CALLAS COURTU SHOICIAL SYSTEM EIETRANICALLY STORED AND PRINTED DICKET SHEETS THIS WILL ALLOW APPEIANT THE OPERATUNITY TO PRESENT UAL EVIDENCE" DIRECTU FERM THE APPEITTE RECORD PRESENTED TO THIS COURT. PLEASE GIVE CARENIT CONSEDERATION TO THE ATTACHED MOTION AND THE APRIC 13,2015 MOTION. THANK YOU FOR YOUR CONSIDERATION IN THIS MATTER. PLEASE FIE THIS COVER PACE AND ATTACHED MOTION AND DERWYN TO AFFECTION of THIS COURT. RESECTSHEE, SUBMITTED DAD F. 15 MAVORITANT
*57
*58 MAY 3.2015
MS LISA MATZ CIVER OF THE 59th COURT OF MAPERALS GOO COMMERCE STREET, SUITE 200 CHILAS TX 75202
COURT OF MAPERALS NO. 05-14-00877-CR, 05-14-00878-CR 05-14-00879-CR, 05-14-00880-CR
TRIAL COURT CAUSE NO. F-DA-55346, F-13-60732, F-13-60733, F-13-72123
RE: DICKET SHEET CALL
DEAR MS. MATZ
ON NOVEM BEX 5, 2014, I WAS NOTIFIED BY THIS COURT THAT ANY APPOINTED APPELANT CAUN SEL MATHEW WITH, HAD AIFD AN ANDERS BREEV WITH OUT ANY CONSENT. TODAY, I COME BEFORE THIS COURT RESUESTING THIS COURT SEED ME A COPY OF EVERY AND SE MOTION THAT HAS BEEN RECIEDED. EISED AND STANTIED WITH THIS COURT IN REFRENCE TO THE ABOVE STYIED CASE(S).
APPELANT PRAYS, THAT THIS COURT PROHIPLY SEED ME THESE COPIES RESUESTED THAT HAVE BEEN STAMDED, AND FIIED BY THE CLERK OF THIS COURT, VERITING THAT THIS COURT HAS RECIEDED THEM ALLTO BE CONSIDERED.
THANK FOR YOUR ATTENTION AND CONSIDERATION TO THIS MATTER. I LOOK FOURD TO RECIEVING THIS INFORMATION IN THE VERY NEAR FUTURE, PIEASE FIID THIS RESUEST AND BRING IT TO THE ATTENTION OF THIS COURT.
RECEIVED COURT OF APPELANT
MAT 072015
Lisa MATZ Clerk, 5th District
*59
NOTES
PESERATING ECOURT
