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Newsome, Edward R.
PD-0102-15
| Tex. | Feb 17, 2015
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*1 Count of Camust. Nibals RECEIVED IN Re: Edward Ro2. Heuson P.O.C. 432859

REB 172015 Taut ouve th 191673 COAP IN-14-20867-28 P.O. DIO 20102-15

FILEYANT COURT OF CERMONDARPANAS Moton For beme to File for A Non-Trait FEB 172015 and A New Enishnent heals

*2

defendant claims to have presented it to the final court see Stokes us state 222 du 2d 20 test can Allag2s August 1888 of evidence allowed at heclans, because there is no fee se Rule that a teal court must hear testmonk whenever there is a fritual dislute in Aftabit on a matter for wee deal and a rnertz Ask for testmonk. A teal court plays its dislute to holdin b heclans when a defendant thesert a thation to be thes teal matter that, mat, not be deternive from the Recald see Holden us state 2015 w 2d. 761 test can Allag2s on Refuest teer heclans on a motio for the thad is not Absolute see Rozelle Us state 1212 in 2d 228, 230 test can Allag2s. Rezes us state 549 du 2d 812 test can All (1993) with Suffertin Attachis Shavin that eave peauled duen's teal on 11-14-1986) see Rozelle 1212 in 2d at 230 when neled 2 d 126 a motion fee a the teal does not canstifute desertment see thenssar us state 253 du 2d 224 test 2d. 769 with doe 28188 . Thesert new dedwents the motion to the canst, as blank the motion to court attempt see Nake 1 us state 956 du 2d 19 test can Allag2s and Rebusar us state 16 du 2d 805 test can Allag2s. The defendant must 洛tam a heclans on the motion betoe the motion for the thit is avilated to

*3 Theatrical of An see/Exar us state 932 S. 4 ad. 93 teK. All Beurnout 1866 Pet. Rel. A theat court, max not Cravt A motion. Rop a New that Rase an Cikounds Not Rased in the motion see state us Reavot as S. 4. 3d.S61

*4 A trial court does not have/anticipated to Grant, A motion for a new trial on its own motion see Hades for a new trial, but A court must Gentian Eliches an which Granting and dening A Motion for a new trial, because/that, and the trial court can not easured it which see extended KWen 924 Siv 2d at 721 because Granting A New A new trial, A Court must Grant A New trial when it has found a melopetous Ground for a New trial, but A Court must Grant only A New A new trial, or unknown when it has found a Ground that affected the assessment of

*5 Reserves of the Tue's that howes the case an Retreat of fowishonst to Pave/mg Wavcewe to Receve A Paidon thenuh the Gowenide; in detemminh the lefiat Sufficere's, to view the Evidence in the hicht most fawwable to the verdict, to detemminel whethow nis Rationel thew of Fants could have found the fesential Elenot of the atferve recond a Rerrenableadast dee/Jauken US Uielousia 443 U.S.327, 319 Jct. 2781, 2789, 61, CEd 2d 560 (1929) Arenst Motion to set Asde conviction, Postwito set Asde veledit, Postuen in ARest of Jodinest pnyl Postan to set Aside and Chash an Fundanentaf deffective

*6 Leuat of Clamuel Mleath Re: Edward Ro\% Mewsme T.D.C 437638 Tead cause 441623 QpA* 14-14-0080008 P D ∘ - 0102 − 15 Ameyded Motion Foe leave to File Dllyed And oOat ACounent in Rulol 38.11h1 To The Haneegsle Tulle of And Louet: The Mlellant Edward R. Mersone ACGue and Retuat foe Reonission to Mleat and tife this blact foe an Oat ACounent in Rulol 38.11h1 and under Rulol 38.11h1 And Rulol 9.5 SeRvice of the Retition, the Reffs And ADO Amendmeit of SuMementation of A Retion of Refls must be made on the stute Resecutin

*7 And CoVchiscar of Imi MANnst Free Statement of Poets in Rulerdod-20.2 and Ruler 38.16, to Resent I sSues of RoNts of EREAR in RulE 38.16 MONnst Cunnnged of ReGugents, From Cess Rnnts Ruler 38.26, for A Re 112 Bchet in Ruler38.3 See Bchet limit of 70 RQes in Ruler 38.1 See ARRondix in cases Recoledated elect Ronicntliz in the trial count in Ruler 38.5 for time to Fie bhet 19 Ruler 38.66 with Motion to Extend tane for Reconsideration in Ruler 10.56 to Ameuf and SuItlenent in Ruler 38.7, for arsibsition Related to mefists an All other clames, an Inilure of AYtellart to File Bhet in Ruler 38.8161.3, t because Bhet are ment to ACCHANt the Count with the issue in A Case arid to Resent ReGunent that will exable the count to decide the case* 14-82 90018-CC in Ruler 38.3. See Recall an Mandate Ruler 18.7 if an Atellate count числе oi, modities its Judiment of oided ther ususis its Mandate, the Atellate cherk must Romflliz motif the check of the count to which the mandate was directed and All Parties. the mandate will have no effect and a new Mandate nase be is sued, and quite bous motelal 2224.5 83 (19e3) the Resecitars has an AFFangtive dutz to tukn ouw Etcul fatae 2 and imenchment eridgice on the 2 uge testmant, 2 uge misconduct in Ruler 606 and Ruler 21.3 on a Recruent for a yau Trait on deadish a videlicet unifaril and Recewink other eridgice when the AYtellart Mexsane Reque is entitled to one

*8 What as of might as manifested for the Saffron Court of the United States, see Douglas US California 372 N.S. 355, B3, S.C. 814, P.L. 22, 2d. 811. unless function the U.S. and the American of the United States constitution mandates that the United Newspore Received effective Assistance of Counsel on his 1st April, as of Sight, and that, should an effect be dismissed for the Parth of the United States, the American of the State Court of All rights, for a full heath of the hearts of the Federal, for a full heath of the hearts of the State of the United States, the Federal of New York, for a full heath of the hearts of the State of the United States, the Federal of New York, for a full heath of the hearts of the State of the United States, the Federal of New York, for a full heath of the hearts of the State.

*9 ACAuitual Interest No Evidence and Also may Ideal Counsel Willan Paul Prewis denied ne/A Fair theal when he Fmled to object to the use of mayfade Enhancement Beadieq? and Etrenous of fesses duand the Rwishoest hering hianed me to Get convicted Atanst Douste Jeolarciz and he Fmled to object Atanst the Juizy thasee would have thanbe theoutime of the Veldict see Mottoy to set asde conducteal Mittor to set asde Veldict and Mottoy W select it Judiment A Canst Motton to set Asde As Enrolanotal detective WeluctmeY, due to wffective Asstance of counsel Fmled to investicate the vithdite of PRIat Conuictions and Etrenous of fesses to adet to their use. The Real conuictions and Etrenous offences Are cven Le zeau old are No Lanker, there to use As Twis hment and may 39 dean sentence is excessive on Refinest to Relase and Remarg for further review. The conviction while inven due to wffective Asstance of counsel has Frealiz still Aunfaste for such use, but here the Ntienter is called to the Atherton of the Real canst. the Bibotant Mersone object on the Cognusis of effective Assistance of counsel Acanst Real Enhancenent PRADEAE and Etrenous offences, in suftiot of m. R. R. Jectian, the statement of facts, the transcinct and may bieret From the Real conviction's and Etrenous offences Atanis with A Cols of the Canst Whian Affremin the conviction, A conviction had with Atheron as Rendeau's wectective Asstance is consttintently iniven see Sekchand vs Moshtoftov treelus see S.ct. 2052, 80, L. Ect. 2d. 624 48599 and Hecyende Us state 2d 624 48599 and Hecyende Us state 2d 624 48599 and Hecyende

*10 A shavic that counsels Refresentation fell Betw in gbitered standard of Rerswabteness and thee deficient Perfformance Residiced the pletove to the deGree-that there is a Persovaste Reaubits that but for the Afrarses defuencis the Result of the treat would have been different and the Result of my Ntreat would have beep diffeceat see C.C. adtude 30.19 not the Bestand A Rersovabe denot standard of fule 44.2 (e) - is the Afrarteste stanfad at inenless eftive Reiven for an undetected tocefce in the treat counts charge that was charned to Uopate A constitutionat Powsion, Seesinwez us state 325 iw. 3d. 233 tef. 22m. 886000). In tefes, the Cminial lay that cokestand to, wifreserved ecefce is called Man effed of fudianertat ecefce. the coust extinued that findanertat ecefce is Jufea chabies, is Revewed Presuast to adtude 30.19 not fule 44.2(e). The eGkelsious hien test is Reifes stanfaded for Reifes when, without ob Dettian; A Jufea chapoe wichide a detentive is sue, but Fats to conan, the detentive is sue in the Affication Research see state us pasfes 9925 iw. 2d. 45 tef. 22m. 886000). The coust decided that Reifes of the Jufea chapoe eche in pasfefes was enticiled by pattude 30.19 and Abraviza us state 50865 iw. 2d. 157 tef. 22m. 8860184). Under Abraviza, a detentive who Confans, on Aftets of an undetected-to eche in the charbe is entitled to Revefes. Nertice hien, stunduged set out in dettude 30.19 as consitined for Abraviza us state 50865 iw. 2d. 157 Nifties unless in Aftetice coust hast finds

*11 elege in the 1wst charge. See Post us state the Cw. ad. 57 for can. 28 (1988). Morthin quitedessin Not Minanza NMS w detemminis whether these was an elege in the 1wst charge. This is because mther, wam stundred to 1wst charge elege set out in quitedessin 19 as cons tened the Minanza NMSies unless the Record first steps that wick Rellurement of various statutent Powsers s difference in quitedessin 19 has been ans Reheated. this, defines the elege for wobse of Minanza. Post, 106 Cw. ad. at 60 May see thatch us state the 242 ad. 166 for can 28 (1988). The suffraenced of the evidence should not be masuee the he 1 wks charge. See Matik us state 953 Cw. ad at 234, 1988. 106 Cw. ad at 462 Cw. ad at 46, the matik decision, avecluded the beysaw - Bozzed line of cases, beysaw us state 666 Cw. ad. at 465, cost. devied that Cw. 1212 (1988), and bozzed us state 712 Cw. ad at 608, the heemless elege rule in Matick, 10612 NMSies. to Mrethate Review of elege in 1 min 6 to recluee a 1 wks instarction calcelain evidence clistined in violation of the law under Asticle 38.23 and AtKusaw us state 782 Cw. ad. 21 for can 28 (1996). on 11-14-1988, no real counsel willan fend news Gmey notice of Mrethate The 1wst found the Mrethate Heusone Guiltz wintelliz Howst wianthodize use of a protee vehicle and the coust Minnted Mrethate counsel Restore wiokz and I wast Adefinate is Reffeated 106 Mrethate Counsel Restore wiokz on Direct Mrethate dukin 30 days record in which to the A motion see new trust and detendint was entitled to remand

*12 to mix cause in order to recommence the time. Period for thin a motel to abate affeal and leave the file out of time. Aftent to file it motel for a few times because without doubt the herein on a motel for a few times. And he is a cating state of the Proceeds. It is the avid Christovist to respect to the that court certain names that may be. Now that, and to make a record on those matters for absolute review. When counsel школы A dater about duwain a sodent, it devied his constitutional fights. Both the Quoted States Sufferer Court and Court of General Aftent have acknowledged that with a "sovident" mutation such as the Actual of consistencies denied counsel of the Criminal Proceeding Residced is Presumed see Spuk us state Let clut 3d at 638. Rule 2 and Rule 43. le to Revense and Remind for Fistles Review) and offer into evidence on astective manst in the court of Aftents Justices, Mfidemic in 2 Died. Aftent on 3-24-1988 and Court of Cawed Aftents Refusio and derisin in 2 Retitial for bis ceterinless Review on 4-12-1988 and Mso offer into evidence on aspective manst in the Court of Aftent Justice Tegot as Chief, Justice Justice and Hecall's dissonis Aftent for most of Inclutation in 102 but of Tive Aftent under ctset 14-11-20867 was None of disctetion, because of the evidence of new is discered evidence cleansstheates by clear and arlinicis evidence that a direct would Occurt the Aftent have on new is discovered evidence, because no Reason able

*13 I've got would have convicted the ill-fast in the war, and I have not been in lichnt of free war evidence, the constitutional efle of the war, and the constitution of one was actually inlevance, because the evidence that was not known to the ill-fast inlevance at the time of that and could not be known to me ever with the evidence of the ill-lence, and I can not here was evidence of facts that were available at the time of 102 Year, the of Gettin, and, for the first time, the of the notion such as Hitler for the first time, and the of the first time, the of the Agrast A-1mscroch of Justice, because I was taken from a time and mindful when I was sentence to an inebal and word 39 dean sentence. See C.C.Leatiche 41, of the All must no evidence, or Vol. 39, of the All must no evidence, or Vol. 39, of the All must inelative. And so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so, so,

*14 ConVict, we has been Gutted of Nist other CoRent conduct, Where Nist natopal witness of the state and defendant has not been theeats we found been Revented from Atendin the Compt, of where Nist evidence tendin to Establish the Whodever of the Acused see Nulttion has been intertowbt to detheated as with the Reventin is Reduction at Nist, when New evidence Favorable to the Acused has been discovered since Nist, Where Nist Retren to detiwonte the Inest has Received thot evidence, of where Nist, as convessed with Nist other Retsov in Reband to the Inset, where the const finds the Inest has, EnCaked in such proconduct that the Acused has not Received A tank and inbotal that and where the veledict is conferees to the law and Evidence, N determinado the le Gal sufficerey to view the Evidence in the 1601 most Favorable to the veledict, to determine whether Nist turn of tracts Could have found the essential Elenest of the offensei beyond a hersevable doubt see Jackson is Vileinla 483 403 307 310 312 323 2189 312 323 326 329 330 331 332 on Refinest to Reve and Remind for a New Treat and New Enishmeat, NINING to PRAVE 212 Whicever under CCTeatide 2129 to Conduct a Clementer NINING for a full rertion for Innocence or All written Recomendation to the TheatCOURT Rn 179 in HORN 2010 17 to the Theat Undie, Disject athever, and sheatt to be tofuated to the TETO, Defintment of COnnpt thitce and to the beead of Retsov and Excites Reconst determination of Nist CUTERITES and conftititical RANTS.

*15 See Perchicb (Sequenciz, Afticatus) Annitis as Revelsat and Penaic For Eclurcton of m 3 Race Clumsal Histed After ACChinat see Ruless:on 2 − 11 − 2015 Date

Celticate of dehance Rule 95 Rule Suspersion of Rules The 180 that edrued R risesone wats the sifutonest

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Case Details

Case Name: Newsome, Edward R.
Court Name: Texas Supreme Court
Date Published: Feb 17, 2015
Docket Number: PD-0102-15
Court Abbreviation: Tex.
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