Case Information

*1 May 28,2015 Court Of Criminal Appieats Of Texas Attention: Abell Acosta, Clerk Of The Cours P.O.Box 12308 Capitol Station

Austin Texas 78711 Re:ExParte Ronnie Boyo Barnett Toes* 1258683 Ward No. 17, 499-A Dear Honorable Clerk Of The Cours, Please Find Enclosed The Applicant's Reply To The State's Drising Answer And The Applicant's Notification From The State That The" Clerk's Record" Has Been Forwarded To This Cours The Applicant's Drising Application for WArt Of Abdeas Cores Was Filed What The Office Of The District Clerk For Pork County, Texas On April 16,2015. He Received The States Drising Answer And Proposed Findings Of Fact And Conclusions Of Law On May 4, 2015 Vix Leum Mail From The Office Of The District Attorney For Pork County, Texas. The Applicant Was Anticipating A 30 Day Period Of Time In which To Respond To The Drising Answer As Well As The State's Proposed Findings Of Fact. As You Can See From The Correspondence The Applicant Received On May 27,2015 Vix Leum Mail From The Office Of The Pork County District Clerk, On May 18, 2015 The Clerk's Record Was Forwarded To The Cours Of Criminal Appieats. Because The Applicant Has Never Received A Court Ordered Findings Of Fact And Conclusions Of Law, The Applicant Reassuredly Assumes There Are No Such Findings Or Conclusions, And That This Cours Will Preceed On The Drising Application. The Applicant Press The Honorable Cours To Compram To The Applicant Tires The Drising Application, According To Previous Correspondence Dateo April 16, 2015, The District Clerk Indicated That If No Order And Been Entered, The Retition Would Be Forwarded

*2 To Tire Lours Of Criminal Apprais For Tireir Consideration On May 21, 2015.

The Appiciant Fustuer Paxis The Honorable Clerk Wile Lompram Thes The Original Application Contains As Paces In The Prescised form According To Texas Code Of Criminal Proceoure Article II, 07 §3 (17Paces) As Wrie As The Applicants's Memorandam Of Lani, Facts Aho Authorities" (13 Del3 Paces), Plus "Extricts A Thruis"

The Appician Unobtrlands The Lours Is Not Recuired To Confirm What Tires Have Or Have Not Received From A Suomittinl Lours Aho Asks Only To Be Certain The Honorable Lours Has Been Provided As Tires The Applicants Has Suomitted So The Lours Has Sufficient Information To Make Tireir Information Ado Just Decision Incluoling Preventing Undue Anxiety Caused By The Appician's Concern That Proceoural Steps Max Not Have Been Correctly Focused Since He Was Not Afforded The Respir Time To Respondo To The State's Cruginal Answer.

The Appician Respecteual Tharks The Clerk Of The Lours In Adverse For Any Repul The Clerk Miant Give The Appician As He Looks Forward To A Possibue Swift Response.

What Best Recuants, Rohme Bovo Baruchit 1258683 Disoue Correctional Center 1604 South First St. Disoue Texas 75941

*3

KATHY CLIFTON POLK COUNTY DISTRICT CLERK

POLK COUNTY JUDICIAL CENTER

CFFICE (936) 327-6814 LIVINGSTON, TEXAS 77351-3233 FAX (936) 327-6851

May 18, 2015 RONNIE BOYD BARNETT TDCJ# 1258683 DIBOLL CORRECTIONAL CENTER 1604 SOUTH $1^{\text{ST}}$ STREET DIBOLL, TX. 75941 RE: RONNIE BOYD BARNETT TDCJ# 1258683 CASE 17,499-A WRIT OF HABEAS CORPUS Dear Mr. Barnett: $$ Upon receipt of proper fees, or a Pauper's Affidavit, the copies you requested will be prepared and mailed. At $\$1.00$ per page, (Govt. Code 51.318), the cost will be $\$$ $$ . Contact the Court Reporter listed below to request a copy of the Reporter's Record and fees.

Your Petition for Writ of Habeas Corpus has been received and filed. Article 11.07 of the Texas Code of Criminal Procedures affords the State 15 days to answer. After the 15 days, the Court has 20 days in which it may order a hearing. If no order has been entered 35 days from the above filing date, petition will be forwarded to the Court of Criminal Appeals for their consideration.

The following instrument has been filed in the above listed case: $$ $$ $$ $$ This date, May 18, 2015, the Clerk's Record has been forwarded to the Court of Criminal appeals.

Sincerely, KATHY E. CLIFTON, DISTRICT CLERK POLK COUNTY, TEXAS cc: Honorable Kaycee L. Jones ${411}^{\text{th}}$ Judicial District Judge C.M. Allen

Assistant Criminal District Attorney Polk County, Texas 101 W. MILL STREET, SUITE 216

*4

WArt No. 17,499-A

ExPANTE In The 4 thth Judicial District Court Of Ronnie Boyd BarnetT Rok County, Texas Apglicant's Reply To State's Drighnal Answer

In Section II Of The State's Drighnal Answer, (Page 2), The First Sentence Wile Reveal The State's Intention To Avoid Addressing The Issues The Appiciant Brings To The Honorable Court And Erroneously Label The Applicant's Many Benuine Issues Of Material Fact As Only One Issue He Has Asked The Court To Address Which, According To The State Is: "The Applicant Claims That He Received bieffective Assistance Of Counsel On Direct Appeal."

While This Is A Very True As Well As Accurate Statement, The Court Only Has To Look To Page 7 Of The Drighnal Application, Which The State Cites, To Find This Association Of Fact, Not Allocation As The State Claims, Is Only In Adoition To The Numerous ConstitutionaL Claims, Violations Of Due Process And Due Course Of Law Claims, Violations (grounded In Statutory Law Provided By The Texas Rules Of Appiciate Procedure, Texas Dode Of Criminal Proceoure, The Texas Penal Code, Standards for Appellate Conouct, And The State Makes No Attempt To Address Any Of These Levitimate Claims Made By The Appiciant In His Drighnal Application For WArt Of Habeas Corpus.

In Fact, The Claims De Violations Of The State Bars Disciplinars Rules for Professional Conduct, Of Which $10r5$

*5 The Texas Supreme Court States Are To Be Retarded As Statutory in Nature, Is The Very Last Claim Made By The Applicant, Yet The ONLY Claim Addressed in The State's Original Answer.

The State's Answer Goes On To State: "The Applicant Does Not Assess That There Were Adorional Issues Applicate Counsel Should Have Raised, But Did Not, That Would Have Resulted In His Conviction Being Drerturned." The Applicant Never Knew What The Drivinal Issues Were, Or How They Were Presented.

The Applicant Will Respectfully Pose This Question To The Honorable Court: "Could A Fair Minded Jurist Reasonably Conclude That It An Appellate Attorney, Internationally Or Not, Withheld Her Appellate Brief, Withheld The State's Brief in Reply, Withheld The Appellate Court's Decision, Never Communicated In Any Way With Her Client, Other Than To Tell Him" That Is The End Of The Line for Appels in Texas," That Because There And Been NO Consultation Concerning Facts Of The Case, NO Consultation Concerning Relevant Procedural Process, NO Consultation Concerning Facts Related To Pre-Trial Incarceration, NO Consultation Concerning Facts Related To Conduct Of Law Enforcement, NO Consultation Concerning Facts At Trial, Conduct Of Defense Counsel Or The Conduct Of The Case, NO Consultation Concerning Post Trial Procedures Or Post Conviction Remedies, That The Applicant Was Not Privileged Nor In A Position To Know What His Right And Claims Were Or Are, And That The ONLY Issue That Is Clear Is That He Has Been Deprived Of His Right To A Fair And Meaningful

*6

Appeal Of Right?"

The Applicant's Claims Are Not A ueogations Accordine To The State, But Are Sufficiently SuBstantiated Facts That Are Firmly Grounded In The Record, And Because The State Refuses To Acknowledge The Claims Clearly Lited In The Original Application ForWrit Of Habeas Corps Is A Sound Indication The State Cannot Contravine These Facts, Hence The Reason They Were Not Adoresed.

The S tatement found On Page 2 Of The Original Answer: "The Applicant Has Failed To State A Sufficient Claim That Would Enitive Him To Relief, Thiefore The Applicant's Eround for Relief Sound Be Denied."

It Is The State's M eritless A ueogation That Is Groundess, AndLens Adequate Discussion Of The Applicant's Claims To Be Considered By The Cours, And It Is Their Request For The Denial Of Relief That Must Be DissmisseD.

However, It Is The State's Next Asserstation That Requires Full Consideration And Sound Be Thoroughly Taken into Account, Founo On Paces 2 And 3 Of The Original Answer, "THE STATE ISUNABLE TO REFUTE THE ALLEGATIONS THAT APPELLATE COUNSEL DID NOT COMMUNICATE WITH THE APPEIEMENT, ADVISE HIM OF HIS RIGHTS OR PROVIDE HIM WITH A COPY OF THE APPELLATE BRIEF."

Pactually, The Applicant Sound Have To Provide No Fusterer Basis In Order for The Honorable Cours To Exaust The Applicant All Relief Requested, But Unlike The State, Wile Adores EaLt Of Their Claims.

The State, Since It Has No Defense To The Applicant's

*7 Honest Assertionk Of Fact, Has To Resors To Question The Credibility Of The Applicants Claim And The Honorable Lours Has To Look No Further Than "Exhort 6" In The Original Application To See That Not Only Is His Claim Credible, But He Should Be Commended For His Compliance To The, Even Thovell It Is Errant, If Not Fradulcant, Faulty Legal Advice.

It Was Only Through A Group Of Concerned Christians Was Were Attempting To Answer Orpenders Legitimate Leval Questions Was The Applicant Made Aware That Not Only Were His Rights Violated in 2004-2006, But The Facts Are His Rights Have Been in A Continual State Of Violation And Remain Being Violated Up To And Including 2015.

Not Only Does He Deserve To Have His Legitimate Claims And Issues Adequately Addressed In The Proper Jurisdiction Of The Applicase Lours, He Is Enitted To It By Law.

Therefore, The Applicant Respectfully Asks The Lours To Dispeeard The State's Original Answer And Any Reply Thes Miant Drive, Dispeeard The Request To Deny Relief, And Erash The Applicant All Relief Reavested And Enitted To, As Wee As Any Further Relief The Lours May Deem Necessary Or Applicable.

Respectfully Submitted, Ronnie Boyd BARNETT TOLs* 1258683 Disol Correctional Letter 1604 South First 51. Disol. Texas 75941 4 of 5

*8

WRI No. 17, 499-A

Ex Parte

Rominie Boyd Barnett Arpucant

In The 4 Htu Crucial Distinct Court Of Pock Country, Texas

Certificate Of Service

This Is To Lertify Thart I, Rominie Boyd Barnett, Tocc $\$1258683$ , Have Delivered To The Office Of The Criminal District Attorney Of Pock Country Texas, Mr William Leellon, Vix U.S.Mail, At 101 West Mill Street, Suite 247, Livingston, Texas, 77351, A True And Correct Copy Of The Arpucant's Reply To Starte's Criminal Answer Thart Was Delivered To Him Vix "Leone Mail" On The 4th Day Of May, 2015, And Have Executen Tuts "Certificale Of Service" On This The 27 th Day Of May, 2015.

Rominie Barmict Rominie Boyd Barnett 1258683 Discll Correctional Center 1604 South First St. Discll, Texas 75941