Case Information

Abel Acosta-Chek of Court Court of Criminal A P Peels P.O.BOX 13308 Capitol Station

Austin Texas 78711

Date: $16 - 17$ 2015 RE: NO: 1328031 -A Yes, Enclosed is an Applicant's 1700 Iron Per Deptent judgment and Applicants Proposed Boder for default Judgment to be filed-stamped dated and set for submission with the Cavet. Thank you.

Sincerely whec 7 1/16/1999 Whec 7 1/16/1999 HAdc 1/1999 Whec 1999 Whec 1999 Whec 1999 Whec 1999 Whec 1999

Wade Jefferson 11/18/04/1 Abb1 Fm 2054 Tennessee Colony, TX 75884

RECEIVED IN

COURT OF CRIMINAL APPEALS JUN 222015 Abel Acosta, Clerk

EXPORTE WAGE JEFFERSON V.

THE STATE OF TEXAS

WHITNO: $222031 - A$

THE HONORABLE COURT:

on September 9, 2014, the trial court of the 238" district court, in response to ABPlicants habeas Petition order his trial attemel Lisa Andrews to file an affidavit for the ineffective assistants of counsel claims. Over 9 months Past the trial court's ordered deadline of outoker 9,2014 and counsel reluctantly failed to comply with court's order.

In response to ABPlicant's witt of mandamus No. WIR-831196-01 this court ordered the Resfendent trial court to either issue findines on ABPlicants habeas grounds and or forwors habeas application to this court. The Resfendent and trial court has preterted to forword all habeas contents to this court without answerins the claims against itself via ineffective assistance, or has the court comfelled trial counsel to answer carrts ordered affidavits nor held an evidentlarthearins against counsels all e eed ineffectiveness.

ABPlicant Recursts that due to counsels silence and failure to comft with the trial courts order to answer the ineffective claims againsther, that this silence will be deemed an acceptance of all ineffectiveness on counsels behalf all e end in Petitioner's Inabeas Petition and memorandum of Law in SuPport, See 8landv.California 20 F.3d 1469 (4" ar 1994 ) (cont den 83 u. 5947 ).

*3 PRAYER

wherefore all premises considered. Afflicant prays that this court will grant motion on its merits, reverse and forward case back to trial court for either new trial or new Pec. or grant relief in accord with which this court deems best.

Respectfully Submitted

Leader Jefferson

Certificate of Service

I wado Jefferson 1810-11 do certify that a true copy of said motion was delivered by Postal mail to Abel Aaosta clerk of court of criminal Affects P.O.Box 12308 Capitol Station Austin TX 78711 on the 17 day of June 2015

Sioned Leader Jefferson

Wade Jefferson 1818-100411

Abel Fm 2054

Tennsse Colon 71478884

WITNO:1338031-A

EXPARTE

IN THE COURT OF CRITIINAL APPEALS IN AUSTIN TEMS

APPIICANIS PROPOSED ORDER FOR DEFAULT JUOSMENT

ON this —dast of 2015, Applicants motion for default statement in his habeas petition against the silence of trial counsels refusal to comply with courts order's to defend against alleged ineffective assistance of counsel claims in a habeas petition Proceeding, and due to counsels silence, is an acceptance of all alleged ineffective assistance claims against by default. IT IS HEREBOROER THIS MOTION FOR DEFAULT JUOSMENT GRANTEO and the trial courts conviction REWERSE and Case RENANOED back to trial court for trial of new Proceeding is 90 or 90 CROBREO

Sicnced on this da4 of 2015

PRESIDING JUDGE