Case Information

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*2 To THE HENORABLE JUDEE LESAID CERT.

Lones Now that Smegean, Complounit in The Above Styled Cause And Files This "Ineffective Assistance of Counsel And legal Mispproches Complaint Against Nicholas Hughes and Melissa Hinzau, et al. And World's Sman the Court The following:

I Paul Smegean, Complounit is curtially incarcerated at the East Carcassum, 1901 Huv 202. The County, in Beville, Texas, 78402.

JL Statement of the FACs On December 2020, that Smegean, Complounit was Judicted for a Fixed Degree felony Whose of Heth. The Judictment Reads as follows:

On the About September 2021, 2022, in Hecess County, Texas But Smegean, did then and these, untruthily Appropriate property. Namely, Lone White White, Lmined By Landy Leal Vanced At over Tainsty Thousand dollars And Under Lone Hunched Thousand Dollars, With The Intenit To deppose Dulner of Property" On June 11, 2011, On The day of Total Joseph S. Wummy was Appointed as Counsel by The Court in Cause No 1180723.

*3 In June 25, 2011, Paul Stangeau, Complnment wiss Convicted of The Phred degree Pebony of Theft of a 2000 Black Heel Hushung Pursued by Dellne, Reaif- A Car Llandy (col). A Crange That is and Included in The Indictment. Punishment who Assessed at Slate Years in the TOCJ-D And A Narc Thousand Dollars Fane.

In June 28,2011, Paul Stangeau, Complniment Tmely Filed a wibltem Abbece of Appeal in Cause no 106725.

In June 28, 2011, Mchasa Mintha was Appomited As Hble deffunder, Counse Ive Paul Stangeau as Appeal in Cause no 1250725.

In July 11, 2011, Mchasa Mintha Filed Airobom Designation of Reoorkess Recoed as Appeal.

In Jn. 21, 2012, Nicholas Hughes And Alexander Bunin filled An Appoote in The Cend of Appeals Cause no 01-11-20075-1970m Paul Stangeaus Bethall in Cause no. 1280725.

JIL Complnunt A. Deutal of Right To Effertive Assistance of Counse/

Paul Stangeau, Complnment asssess that can A bout Jn. 24, 2012, Nicholas Hughes And Mchasa Mintha, etal. Instantiously And Kaminingly Worried Paul Stangeau, with And fancieasly Amendrimal Rughts quarmaker/And

3-OF-II In Abme, is unable To Assist The defendant To Eeffert A fane decision as Neels.

There Are Two Types of Case Recognizing The Right To Counse?, Mcha Fied Appeal as of Right and The Cases Recognizing The Right of Counse? Af tual includes the Right To Effective Assistance of Counse/ Are Dryustive

*4 Bottetel by The. State of Tens And The United States Leasblation, without The Efective Consent of The Appellant Paul Surgeon by Nianely, Duling to/ Refusing to File Anchainingb/ Appell in Cause no 100723, Count of Appenh no. 01-1100575-221 and completely Failed to Subtert the Pasecutions Lase To Mreaningful Adversaral Testing Dining the Appell. Theedy denying Paul Surgeous Light To Actual and Resungitive Effective Assistance of Cunisel, Nithohs Hughes and Melissar Phentais, etals. Reference Recubiced Paul Surgeous Case in Cause no. 100723 (Count of Appenh no. 01-11-00575222) Affecting the outcome Un Appenh. Nainilating into a Unibumental Miscarriage of Justice, press niagigance And Legl) Mappentice.

Standard of Review: "The Defendants Liberty Depends on his Abilify To Pasecut his Case in the Face of "The Jutteracies of the Law And The Adverney of the Public Pasecutor" See United States v. Ash. us us seou 201925.21256232 Ledze! 649 (1972). Pecause The Light To Leunisel is sobundamental To a Fair Teal The Constitutiona Comnul Toterale Tools in Which Leunisel, Though Pasecut In Abme, is unable to Assist The defendant To Ubbind A Fair decisioni on Meisls.

These are Two Types of Case Recopueing The Light To Leunisel, T Dus niest Appenh as of Bight and the Cases Recopuiring the Light of Leunisel at teal includes the Right To Effective Assistance of Cenusel. An Disjustice

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Of Bull 5 rurgeon's Complaint. In Bringing An Appical as of Right Penn bus Conviction A Criminal Defendant o Allempling to Demonstent. That The Conviction with its Consequence Denstic. Icss of Liberty is Unilatual To Resecufe The Appical A Cerminial Appellant Illust fice An Adoessary Proceeding That Like A Tenil is powery by Intericate Rules that A Lay Person Would be Impelessly Forbidding. An Unifepresentent Person! Appellant-Like An Unifepresentent Defendant At Tenil is Unilable To Protect The Vital Interests Al Stake.

Ground One of Complaint:

Bull 5 rurgens Assets Thal Alcholis Hughes and Melissa Mithun, et al., Intentionally and knowingly Refised To Model To Include Inetfective Assistance of Countef As A Ground fere Bull 5 rurgens's Appenl in Cause no. 1180723. (counel of Appends No. 01-11-00575 22).

In The Reveit Case, After Revealing The Cenit Repojeres Tovil Records Which include the State'Prosecutors like in Cause no. 1280723, Alcholos Hughes And Melissa Mithun, et al., Knows and Should have knowus:

1) Thal On Juic 212011. Joseph S. Unimity was Appoinled Countef in Cause no.1280723, About Four times before tenil Begins. After The Cenit Appoinled Countef, Pail 5 rurgens filed A Mithun for Confinamnce. (see Hures Counly Cominial Drisiel Dectel Steel Ages 3 of 5). The Cenit Deuiel Bull 5 rurgens's Mithun for Confinamnce. Bull 5 rurgens Uesterred.

*6 'Sexual of Ten-day Allowed Level Appointed Counsel To Repose For Total Wointed Stitute and Inferinged Rights of Mupee Acessed To Assistance of Counsel for his Defense undere Sixth Amendment To The Constitution of the United States, USA, Cossi Amend G. Veaceus Anur. C.C.P. Ad 174 E. Prete Godel, 368. S. 432 ff. Absent Shoriting That Judgess' defassionis Level Appointed Counsel, Who was Appointed Dially Tral Commenced, had sufficient Time to Repose for Total, or That defassionis And his CaretAppointed Counsel Wraived his working Time Reovided by Land To Repose for Total, A Reversal Is Required. See Censual Law Lop tel 3 (2) Veacous Anen. C.C.P. Ad 16 or (6) ined Eenthees 8 State 480 s. 222246

Because Joseph S. Dunning was Appomited on the day of T'eial and did not have The Requisite Minimum Amount of Time to Investigate The Case And Repose for T'eial, The Caret-Appointed Alloratory was undecquately Reppened for T'eial. Relief Reguined See Hearing 8 Estelle, 491 Eed 125

Because Joseph S. Dunning was Appointed Counsel on the day of T'eial Counsel was inctfective because Counsel was uninble To Spend Time with But S'turgeon or Do the Case, withct thinte if impossible for Counsel To Adequately Advise that S'turgeon. Relief Reguined See Weller V. Caldwell 476 Eed 215

But S'turgeon Assess that had this spennd been disclosed To the Caret of Appeals in The Appeal in Causerib. 188073 Appeals Caret us. D-11-8057s-22) If woutd have changed the Caret's Veredict And The Outcome of The Caret's decision in But S'turgeon's Appeal.

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*7 Second Two of Complaint: Paul Stuegeou, Asserts that Alcheks Hughes and Michssa Minotia etal, Infertionally and knowingly Retised United te in Chute fundamexitally defective and Iuvinlif Iudictionent is A Censual in Paul's Tuegeous Appetion Cance No. 128023. (Appeal Comil No. 011102575-C2). In The Resent Case, After Remewiting The Caret Repoxters Teral Records which inicludes The State Reseraticis file in Cause nic 1002723, Alcheks Hughes and Michssa Hinkhacel al., Tutewis and. Shendel have knownent: A The Charging Iustemment in Cause no 100723, (the Iudictionent) b Completely and fatally defective As much so. That Hides Aest Boutly As No Iudictment, As detined by Terss Canss. Aet. V 3 relled Because if Completely failed to Charge Paul's Tuegeous. B) The Iudictment Reads as Retious: "Case About September 2, 1010, in Hancs County, Terss, Paul Stuegeou Did thent and Three Unthastully Apprepante ptequely, asimely, Due Hider Vehicle, Unwed by Landy Leal, Valued At Dive Tracely Thentand dothes and thades Due Handed Thensmied dothes, with The inText Tredspove Index of Repetely" In The Resent Case Paul Stuegeousisdestined and Comnited of Theft If A Tiro Blue Read Dicslong, In The Iudictionent, The State Pat nic Evidence of theft of A Tiro Bluek had Dicslong Heusites it Alloge that Paul's tiveneer, Nited

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Intentionally and knowingly who does it Alloge that Paul's'megeon Apprepented reguengly without the Effective Bausert of Moons. C) Pecane Ladictaneit is inivahid The Coues Lacked Juposbicies? There thul's'megean's Convection thud Jastence is Unimittoorized. Hud Requies the Automatic Reversat and Agorilat see Washingteis. state. 4095 wizd ST7 i. 160110 V state. 4095 wizd ssle i Ladictaneit Tulbomabord Rev 169 (1) i Veruous Anat Ter Coust Aad 531216 D). Puls'smegeon Whs Conucted Aud Sentence without Hu buictment Which Allowed The Juey To Comicld bised Solely on The Ctrenge And Evidence At Teal Which does Not Concessant to the Iudictancat. This Requies Au Automatic Reversat Reprobless of Harm dase To Paul's'megeon See Monstoyas V state. 8955 wizd 916 i Babst V state UTI sinled ST3 iand bled v. state. 5205 wizd 395 Whhource Aseels that had This Second Beu discteert in the Appent To The Coust Appents in Couse 40.118072 (Counal of Appent) 40.111188575.8el It Weuld have Ctrange the Velelici And The Euterine of Paul'smegean's Appent. Decous.

Second Three of Complaint: Hul'smegeon asserts that Niebieus Hughes and Melissa Phaitins. et al., Intentionally and knowingly Refused Plated to intchude "Actual Juuorcease" us A Decound in Paul'smegean's Appent in Couse 40.128072 (Appents 40.1211188575.80)

BIOFII

*9 In The Peasant Case, After Reviewing The Couet Repealers Total Records Which includes The State Researcher's File in Cause no. 1280725 , Nicholas Hughes and Melissa Mrether et al. Knows And Should have know.

That Paul Struger is Relually Immacen? At Total, Paul Struger was Aecused of And Convicted of Heff by holding a Ene, held under A written Eaithl Agreement beyond the Expatation Period.

This does not Constitule Theftememe Prevenn? To The Eaithl Agreement no. 4009457-4, Paul Struger's had evinies effective Context to exercise Control over 2000 bhelt level Hlestung. Theft Can Luly Beem When the After Tole Resewant Repeely Sreetly, Without Right or Love Of Dutures Laresit see CECCV Hopkins US slat 2d 28; Themasen v.Side, 800 S.m. 2d 8 ; Wlashughou V.Side, 800 S.m. 2 d 522; 800 S.m. 2 d 74 And With v.Side, 200 S.m. 2 d 161

Yers Paul Code see.31.85, Does not Apply To PaulSrieger's Case in Cause No. 1280725 .

Relivence Assets That had Nibhelos Hughes And Melissa Mrether etal., include This geaund on Appenl Along with With Teers Paul Code 31.04. If wlouth have Churgent the Veetle? And Letlenme of The Appenls Couets Decisions in Cause no. 1280725 (about 91 Appenls no. 01-1200525-28)

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I. Hail Stumptow. Has Reportedly Attempted To Contine? Nicheths Hughes And Mebissa Manhz. et al., in Hail Attempt To get Assistance in Powinging My Imbocence And Obtinueing My Release, but There hasn't been Any Response. To my Attempts. I've Also Requested Assistance in getting branch Unnervited back to Hinews Lownity, Jail, Hines Lownity, Ieans but, I've Recever/ No Response or Assistance from, Nicheths Hughes of Mebissa Manhz.etal,

Prayer for Relief

Witherelue, Complninnis, I muing Shown That Just Louse exists For Finding That Nicheths Hughes And Mebissa Manhz. etal, IWtherhowally And Rwontingly Violated Hail Stumpans Staitirely And Releally Rejected Sixth, eighth mad Fountecith Amendmeat Rights To Actual And Rewmmative Effective Assistance of Lounsell Lgual Rotections, Rotections Against Level and Unusual Enwishmeat, and Due Races of Lnw withen The Respondents Infertionally And Rwontingly Refised /Hated To File a Measinof Eal Appen in Lube No. 1280723, Lcowd of Appenh no. 01-11-00535-28) On Hail Stumpers Dehalf, further, Comobiannst Pany That This Lcwit Rinds That The Repponition's Efficient Rewthmative Reexudieed Hail Stuegceats Lne on Appenl And Affected The Unleome of his Appenl. And That Reiponition's Refinus Constitutes Lhoss Negligence And Legal Malpractice And Aetial And Resumptive welfective Assistance of Lounsell, Ial Appenl.

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And Luda Respondents To Mssis Comphusant in may hact All Erethel Recackings,

Lmphimant Preever give Prays. Sigued on this The 15 th Any of Masech 120.15 .

Declanation

I. Pual S'megecu do detree undue hailly of Reauey That The inlcanation, Statements nild fects included hecein the Tene huct Lomect To The Best of My Anomiledge.

EXECUTEN ON This The IS th day of abaccts 120.15 .

*12 Lentifante d'Servace I. Nul's'rogeous. de heechs ceitity that Allprabies has becasevied by Mincing The Original Lopy and Due Tene And Lornet Bopy of The Longdunil in Cause No. 180728 lound of Appols no. 01-11-18555 (c) in The United States Maid with Paper Pashage Affixed And Rensineded To: Faxilowith Eend of Appouls: Elek Choisipahes A. Pane, 301 Enwisist Don 245 , Henslow Texas 77002 sigued on This The 3eth $$ day of March $$ 17015.

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Beau Hauf 182 Beauille. Tents 78182

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Furiteunth Cent of Appents

Llerk

Chroletpter A. Pane RIN 245

361 Funuin 51. Hausleu Tons 140171102