Case Information
*1
"Evidentiary Hearing Requested"
Motion to Re-hear RECEIVED IN WITTION DERHE! WITTION DERHE! To The Judge of said Court. DATE: BUS 3.6
Comes Nov Keith Stuart Cunbee, Applicant Fig Se, in the above entitled and numbered Cause and Submits this his" Motion to Hehear in Support of his application for Writ of Habeas Corpus and will respectfully show the following:
*2
Facts of the Case:
January 3, 2006 * Sentence Emposed * Sentence Commenced * kauyer: William Brandon Baade
January 29, 2007 * Application to Hoced to Final Odjudication February 1, 2007 * Order Opphication to Hoced to Final Odjudication February 2, 2007 * Aljas Cabias Issued * Notice Issued
January 13, 2011 * Arrested
January 14, 2011 * Order-Opopinting Attorney- receive Jackson Order-Setting Hearing
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February 18, 2011
- Judgement in Revoqation
- Order Final Qdjudication
March 2, 2011
- Enfor mation - Case* 007-0219-11
- Order-Appointing Attorney- receive Jackson
- Order-Setting Hearing - Plea Sentencing
March 1, 2011
- Plea Sentencing
March 18, 2011
- Judgement
This Applicants February 16, 2012 and October 11, 2013 Tilings astached attorney William, Brandon, Daase and the conlictiof and Sentence of January 3, 2006 and nothing else.
*4
On the dates of:
January 29, 2001 February 1, 2001 February 2, 2001 The State took steps to withdraw from any and all agreements made with this applicant and his attorney William Brandeh Baade on January 2, 2001 in a sense making three proceedings. Void. ( 10 years probation off the table).
January 13, 2011 * applicant arrested
January 14, 2011 The Honorable Judge Kerry Russell appointed Austin Freely Jackson to this applicant as counsel for the NEU proceedings i.e. Plea Sentencing.
*5 On February 14, 2011 this applicant and attorney (Justin Reeve Jackson) stood before the 7th Judicial District Court of Smith County. Texas was found guilty in cause no. 00-1-1320-03 (agravated default and cause no. 00-1-0219-11) (loss of Marri) and was sentenced to a new lawyer in the Texas Dept. Criminal Justice See Order of Final Adjudication-Filed Feb. 18, 2011 pages 30,31,32 of this filing).
This applicant group's this is a new proceeding a new attorney with new charges added (007-0219-11) and in the way be attached to any other proceedings or filings. All factual allegations are new and had only to the proceedings in February 2011 and attorney (Justin Reeve Jackson) (this, a new conviction and this applicant's "One bite at the apple" Ex parte Whiteside 12 S.W. 3d 319,320 (Tex Crim. App 2000); Ex parte Torres 943 S.W. 3d 469,414 (Tex Crim. app 1997).
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Prayer
Wherefore, premises Considered, this Opplicant prays that the Court finds that there are many controverted unresolved facts material to the fegality of Applicant's Contingent, that there is a great necessity for a fact finding hearing so that all evidence can be brought to fight and this Honorable Court can reach the merits of applicants Clairn Respectfully Submitted, Ruth S. Cumlwe 1699482 Waune Scott Unit (0499) Netrieve Rd. Angleton, Texas 71515 "Evidentiaay Hearing Requested"