*1
JN CAMINAL DSTRICT CONT N3 3 DALLAS CAUNTY,TEXAS
APHILANTS RESPONSE TO STATES
PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW CONES NOU, SENFICK WILKERSON, Applicant in the above stylet and numbered course, and fites this, his response to State's proposed findings of foet and conclusions of law, and will shaw in support as follows:
- Applicant objects to the State's proposed findings of foot, conclusions of law, and order. Applicant's due process is constantly denied and yictated.
- Applicant finally received a copy of the Clerk's record from CAUSE NO, FIO-CURES &; FIO-CURE, which was incomplete. The Fifth Court of Appeals in Dallas continued to ORDER the District Clerk to forward the Clerk's record, and finally it was filed in May of 204. Therefore, in June of 204, appats counsel Michael Malula Forwarded Applicant the Clerk's record. The Application that was filed in February of 2015, was for Applicant seeking an out-of-time appeal, and not a subsequent writ.
- Applicant continued to request the fites, records etc, etc, from the State, but was always ignored. An attorney from Dallas County led Applicant to the information about the missing documents, and the missing files in the record.
- It is totally impossible for Applicant to establish that, by a preponderance of the evidence, but for the vidation of the United States Constitution, no rational juror could have found him quitty beyond a reasonable doubt, when the State will not forward Applicant the Brady Material, and or the Discovery for ROOLES sexual performance by a child.
Pup 1 of 2
*2
- Applicant respectfully recommends the relief of this wint of Habeas Corpus, and that an Evidentiary Hearing be immediately set, in the interest of justice.
Respectfully submitted, SENARICK WILKERSON J 1885146 Ramsey I Unit 1100 PH 655 TE-2-17T Rosharon, TX 77583
CERTIFICATE OF SERVICE I hereby certify that on April 24, 2015, the foregoing document has been U.S. mailed to: Felicia Patre District Clerk, 133 N. Ruerfiont-Blud, 1812, Dulles, TX 75207 &; Court of Criminal Apeals, P.O. Box 12308, Austin, TX 78711.
SENARICK WILKERSON
RS. Sheppard my liberty
