Case Information

*1 Tilton Grigg's VS. tate Of Texas

FIECEIVED IN The Court of Atmeals Satin District JUN 152015

Tecarkana, Texas Debra Autrey, Black Now Cones the Appellant, Milton Edwardte Grigg's, Appellant Fite his Motion For Brief In Prayer Of Accreptance

| | | | :--: | :--: | | | Texarkena, Texas Debra K. Autrey, Cterk |

On Feb, 13, 2015 and In the County of Hunt, Hunt Canity Court at Law No* And before the Honorable Judge Timothy S. kinder I, Milton Edward Grigg's, Appellant In Abave said Refermord Case fmy being Represented by Attorney Jack L. Paris, was Intact sntmord to 300 days In Hunt County Jail after being talked Into Doin' on Open Court Plio to fef before the Judge Timothy S. kinder by his Attorney Jack L. Paris, on his misdermranor oftence of Failure to I.D. an Allergd Class R misdemeanor oftence, Inwhich I. the Appellant, Milton Edward Grigg's, Abad Guilty to such oftence Nor Never Knowing fof Ever Being made Aware of such offtense Being Enhanced by the State Peded! By my Atternys Jock L. Paris. I, Appellant Filed Appeal Feb. 19, 2015 after being Drvind Work Refresc and the Courts Appinted Jussica Edwards to represent me on Appeal.

April 6, 2015 My Appinted Appeal Atty. Jussica Edwards Withdraws from my Appeal. Lraving me to File my Brief fdoall Legalism Myself.

*2 Apprllant was arrested and charged with Failing to I.D. Only: August 4,2014 I was Wror Under Arrest, Wor had I Eure bren Detalind by the Grenmillr Police Department, Wor aware that I Eure nad any Wacant for my Arrest Upon my Falling to I.D Officers where constantly being Maliciously dispatched to trprllants Residunt on Falsr Acousations of Demostie Violence As well as making False Acousations to Appellants Probation officer Brent Gibson [3re Attachad Records titled Exhibit K] Forther A review of Grenmillte Police Records would forthe support and show such Truyf Carest In which they to disearred such was Wrwer True mraning (Demostic Violence) During the Date and time in question August 4, 2015 I Gave Falsr Iden'ity due to Grenmillr Police being constantly called out for false calls of Demostie violence f At such tine Robyns feet where Bodly swollen Due to ther Pancreas being Infectedf the Having Nobody around to help her I Frered thry was their for another False call. I was Wrwer arrested of Retained and upon thesy of ficers coming back Yet Again I told them Who I was. I I Drmlled Myself! And the officer stated I thought you said you was Reginald! For these officers had left and came Back a 2nd timef I was then Arrested.

*3 Apprdant Hrreby Ask this Honorable Apprals Court to Review the following issurs. Overturning such wrongfol Enhancement? Punishment in Excess.

I was arrested on Failing to I. D. and Arroined on such by the Justice of the Peace on A misdromance offense beings Class B misdromance

I Prefressed on PR. Bond having such still be Class B. misdromenor.

I was Wywe made Aware of such being Enhaned by my hngor Pedad. Upon my Phading Guilty

My Ahorrey was never on tine and such case kept being put off and went brtore Jdiffirmt judges. To Wit for Mamey Judge Andrew Brench Judge Doncan F. Thomas, f the Mroly Appointed Judge f sentrincing Judge Judge Timothy S. hindon.

I Agreed to Plead Guilty to that of A Class B misdroman offense of failing to I. D. and D. ot that of A Class A misdromenor that I had Mo Knowledge of such Being Enhaned. For such wastir what I PR oust on as wel sre A ttochrd Documents Exhibits A, Forthin soch Exhibits shows that such was done After my being refresed on PR. bond. Appellant further Request that this court Obtains a full Record for Review and in support of my Aperal and Exhibits.

*4 Furthermore My Attorney stated that the States other was Less than he Punishment imposed yut the County Attorney requested that I be entenced to I year in Jail although I was given 300 days. My Lawyer stated that I was offered 180 days, then such went to 270 days in which I Refused and Had requested A Jury trial. But was instead talked into Ding an Open Court Play before the judge. I had first Declined such and was told by my Lawyer that I stood a good chance at going before this judge, My Still thinking that such was still A Class B misdrumsance and having been told that at worst I could only receive a Maximum of 180 days in Jail I went for such. Only to be Sentenced to an Excessive 300day and Never being made Aware of such Enhancement until After All had been done and my Not understanding the Judges 300day senterally and how he was able to do such if such was only punishable of up to 180 days. I Immediately asked for Appenl. For I have Plend Guilty to a totally Different charge that was in fact switched on me and in which I had No Knowledge of at All until after being sentenced. My Attorneys Counsel was very Defective.

*5

Prayer For Relief

I, Milton Edward Grigos Hereby Pray that this Honorable Judge of this Court of Appmals Upon Review of my Brief $†$ Records Find and Warrant In My Favor that the Court $‡$ Judge as per my Attorney has Infect Errored and Quecturn my Sentencing and that such be Reduced to 1/2 the 300 days original sentence Rendering Appollants Sentence to 150 days Jail time. And that this Honorable Court Judge render Any $‡$ All Wecerssary Corrective Actions Dermed Appropriate to End such Wrought. Undercover acts of Enhancements by the State. Drinking all Weecessary Correctiwe reans Wrecessary. Wherefore Appollant. Pray this Court Grant him Relief? Submitted this 11th Day of June 2015.

Respectfully Submitted Maton Edward Grigos 25741 Milton Edward Grigos Hint County Jail 2801 Stout St. Greenville TX. 75701

*6 Miltan Grigas vs. State Of Texas

Lount of Hifteals 6th Appellate District State of Texas

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I the Appellant Horky submit this written Instrument In Strong Hope, if sincerely Fray that this Honorable Appeal Count Grant Appellant and or Rinder some form of assistance for this issue at hand. Such is as Fallows?

1. Appellant filled Appeal with this Appeals Court.
2. Appellant was Granted the Right to Appeal and was appointed Counsel Ssssice Edwards Feb. 14, 2015
3. April 6, 2015 Sssice Edwards Withdrew from 8 my Appeal leaving me Alone with No Ruprorotation.
4. Appellant has written the Courts All to No Avail.
5. Appellant was Dynind Access to a law Library and was denied such.
6. Appellant filled a motion with this Honorable Court of Apps for Injunction and such was Granted.
7. On May 6th 2015 Appellant was taken from the jail to the courthouse for a 4 hr law Library session, being allowed the use of 1 hand only For officials are exciting Appellants left hand to waist revolving such of No uss and makes it almost impossible and very very straining to get a book write eet. ect.
8. Appellant received 3,300 hr. sessions under such strainfol handcuffed conditions Having tried to do the best he can I Horky have this Court for Assistance for Legal Ride.

*7

Appellant is not an Ahorrey's knows little about havjboring Incarcerated fuvy very limited to Access to A Law Library has irnduced Appellants rights to property file his Brief in support of $eR$ Property Approl his case.

Appellant knows very little $t$ Is asking this Honorable Judge $t$ Court of Approls to Accept the Attached Hereto written Instrument As his Approl Brief. For I, Milton Edward Grigos Appellant is Infect Incarcerated at the Hunt County Jail in Grenville TX. and is Unable to Afford an A Horrey for his Approl's Brief.

Prayer

Wherefore I the Appellant, Milton Edward Grigos Pray that this court of Approls Grant Appellants Motion for Appointment of Counsel $t$ OR Grant Appellants written Instrument As his Brief In Support of his Approland Duveturn his Sentence.

*8 Centificate of Service I, Milton Edward Grigg's Hereby Certify that A Truel Correct Copy of Appellants Brief to the Best of his Ability? Prayer for Acceptance by the Court for His A Hornry has been mailed this 11th Day in June 2015.

Respectfully Submitted Milton Grigg's Milton Grigg's Hint County Salt 2801 Stour 3 St. Greenville TX. 75401

*9 $$EXh:b,+\int$$

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*10

CASE # CR1401075 CAUSE: FAIL TO IDENTIFY FUGITIVE INTENT GIVE FALSE I STYLE: THE STATE OF TEXAS VIS MILTON EDWARD GRIGGS

DEFENDANT

NAME GRIGGS, MILTON EDWARD D 2310 HENRY ST GREENVILLE , TX 75401

TRANSACTIONS FOR ALL PARTIES

08/06/2014 GRIGGS, MILTON EDWA 08/19/2014 GRIGGS, MILTON EDWA 08/19/2014 GRIGGS, MILTON EDWA 08/29/2014 GRIGGS, MILTON EDWA 09/05/2014 GRIGGS, MILTON EDWA 09/30/2014 GRIGGS, MILTON EDWA 10/02/2014 GRIGGS, MILTON EDWA 10/30/2014 GRIGGS, MILTON EDWA 11/04/2014 GRIGGS, MILTON EDWA 11/20/2014 GRIGGS, MILTON EDWA 11/20/2014 GRIGGS, MILTON EDWA 01/06/2015 GRIGGS, MILTON EDWA 01/08/2015 GRIGGS, MILTON EDWA 02/02/2015 GRIGGS, MILTON EDWA 02/13/2015 GRIGGS, MILTON EDWA 02/13/2015 GRIGGS, MILTON EDWA

ATTORNEY

PARIS, JACK L. JR. 3101 JOE RAMSEY BLVD., STE. 101 P.O. BOX 8277

GREENVILLE, TEXAS 75404-8277 903-455-5797

REPORT FOR ALL DATES

DECL INABILITY TO EMPLOY COUNSEL, ORDER APPT ATTY, J. PARIS,FAX CONF, RESET 8/8/14 9AM BOND HRG/C T ORDER CONCERNING BOND-$1500.00 PR BOND,FAX CONF TO JAIL/C T PR BOND,FAX CONF TO JAIL/C T COMPLAINT, INFORMATION, STANDING ORDER BOND, ORDER CONCERNING BOND SET PER NOTICE LETTER 9/30/14 9 AM/L A REQUEST FOR NEXT COURT SETTING/ORDER RESET $10/30/20149$ AM/L A SET PER NOTICE LETTER 10/30/14 9AM/C T REQUEST FOR NEXT COURT SETTING/ORDER RESET $11/20/20149$ AM/L A SET PER NOTICE LETTER 11/20/14 9AM/L D REQUEST FOR NEXT COURT SETTING/ORDER RESET $1/6/20159$ AM/L A SET PER NOTICE LETTER 1/6/2015 9 AM/L A REQUEST FOR NEXT COURT SETTING/ORDER RESET $2/6/20159$ AM/L A SET PER NOTICE LETTER 2/6/2015 9 AM/L A SET PER NOTICE LETTER 2/13/15 9AM/T L DEF. PRESENT, PLED GUILTY,WAIVED JURY,CC-237.00 ATTRY-1985.00, 300 DAYS JAIL 16 DAYS TIME SERVED. DISPOSITION,JUUGMENT/SENTENCE,DOCKET, CERT RIGHT TO APPEAL, PYMT FEE VOUCHER, BILL OF COST./L A WAIVER OF RIGHTS, CONFESSION AND AGREEMENT./L A

*11

THE STATE OF TEXAS v.

MILTON EDWARD GRIGGS

COMPLAINT

in THE NAME AND BY AUTHORIFY OF THE STATE OF TEXAS

Amenda Henderson, solemnly swear that I have good reason to believe and do believe that MILTON EDWARD GRIGGS, hereinafter called Defendant, heretofore, on or about the 4th day of August, 2014, before the filing of this complaint, in Hunt County, Texas, did then and there, knowing that the said G. Barrow was a peace officer, intentionally give a false or fictitious name and date of birth, to-wit: Reginald Kinchen DOB: 10-07-1978, to G. Barrow, a peace officer who had lawfully arrested or detained MILTON EDWARD GRIGGS, and MILTON EDWARD GRIGGS was then and there a fugitive from justice.

Complainant bases his/her belief upon the observations of G. Barrow, a peace officer, obtained by reviewing said officer's report:

AGAINST THE PEACE AND DIGGNTY OF THE STATE

CA 149923 FAIL TO IDENTIFY - FUGITIVE FROM JUSTICE CLASS A

*12

CRIMON

THE STATE OF TEXAS

V.

MILTON EDWARD GRIGGS

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS

IN THE COUNTY COURT

AT LAWNO. 1 HUNT COUNTY, TEXAS

INFORMATION

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS

1. Joel D. Littlefield, County Attorney of Hunt County, Texas, presents in and to

the Hunt County Court At Law No.1, that on or about 4th day of August, 2014, and before the filing of this information, in Hunt County, Texas, MILTON EDWARD GRIGGS, hereinafter called Defendant, did then and there, knowing that the said G. Barrow was a peace officer, intentionally give a false or fictitious name and date of birth, to-wit: Reginald Kinchen DOB: 10-07-1978, to G. Barrow, a peace officer who had lawfully arrested or detained MILTON EDWARD GRIGGS, and MILTON EDWARD GRIGGS was then and there a fugitive from justice.

CA 149923 FAIL TO IDENTIFY - FUGITIVE FROM JUSTICE CLASS A

*13

IN THE COUNTY COURT AT LAW NO. 1

&;

IN THE COUNTY COURT AT LAW NO. 2 OF HUNT COUNTY, TEXAS

STANDING ORDER IN ALL CRIMINAL CASES

On or before the date scheduled for the Defendant's first status or arraignment hearing in all criminal cases now or hereafter pending in this Court, the State, through the office of its Hunt County Attorney, is ordered to produce and make available to the Defendant's Attorney at the office of said Hunt County Attorney for inspection and copying and without the necessity of the filing of a motion for discovery or production thereof, or by posting same on the County Attorney's Case Search (HCOCS) website the following, to-wit:

The criminal arrest and conviction records (criminal history), if any, of the Defendant. The purpose of this Order is to eliminate the necessity of pretrial hearings or the filing of pretrial motions related to the discovery of the Defendant's criminal history.

It is further ordered that the Defendant's Attorney is prohibited from disseminating and/or distributing the criminal history record to anyone without further order of the Court.

This order is effective the $1^{\text{st}}$ day of August, 2012 and shall remain in full force and effect until altered, modified, or rescinded by the Court. The Clerk of this Court shall cause a copy of this order to be filed in all criminal cases at the time that a complaint and information is received and filed by the Clerk of this Court.

Honorable F. Duncan Thomas Hunt County Court at Law No. 1

Hunt County Court at Law No. 2

*14 I. Whthen GQTIP2 as principal herein, am held and firmly bound unto the State of Texas in the just and full sum of $s$ for the payment of which well and truly to be made, I bind myself to appear in the Hunt County Court at Law No. 1 when summoned.

The Condition of the above obligation is such that, whereas the above bond has been entered into by me, having been charged with a misdemeanor, to wit:

Now, if I, the said Principal, shall be and personally appear INSTANTER before the County Court at Law No.1, $4^{\text{th}}$ floor, Hunt County Courthouse, Greenville, Texas, until discharged by order of the Court, to answer the aforesaid accusation against me, and shall personally appear for any and all subsequent proceedings had relative to the above charges, and before any Court or Courts of the State of Texas in which said subsequent proceedings may be pending, and not depart the Court without leave; and further conditioned that I will pay all necessary and reasonable expenses incurred by any and all sheriffs or other peace officers in re-arresting me in the event that I fail to appear before the Court or Magistrate named in the bond at the time stated therein, as well as before any other Court to which the same may be transferred, and for any and all subsequent proceedings had relative to the charge, then in such case the bond will be null and void, otherwise to remain in full force and effect.

I swear that I will appear before the Court designated in the preceding paragraph or pay the Court the principal sum of this bond plus any reasonable and necessary expenses incurred in the event of my arrest for failure to appear as required by this bond.

IT IS THE DUTY OF THE PRINCIPAL TO IMMEDIATELY NOTIFY THE COURT OF ANY CHANGE OF ADDRESS.

WITNESS OUR HAND, this 18 day of $BopeS22012$

THIS MATTER IS RESET TO:

at Law No. 1

Phone

DOB: 3-41-21 Place of Birth: Eoronville 74 DL No. 025195200

Sate: $X^2$ Weight: 188 Eye Color: 8000 Hair Color: ${8000}^2$ Employment: $$ Address: $$ Business Phone: $$ Nearest Relative: $$ Address: $$

*15 IT IS FURTHER ORDERED that as condition(s) of this bond, the Defendant shall: [] Submit to home curfew and electronic monitoring under the supervision of the Hunt County Community Supervision and Corrections Department (HCCSCD). Not leave Hunt County or county of residence without written permission of HCCSCD or the Court. Submit to testing as directed by HCCSCD for the presence of controlled substances in the Defendant's body. Abstain from the use of alcohol and controlled substances while this case remains pending. Not directly or indirectly communicate with $$ , the alleged victim in this offense, and shall not go near a residence, school, or $$ $$ frequented by the alleged victim or the alleged victim's family. Work toward obtaining a high school diploma or equivalent. Not commit a new offense against this state or any other state or of the United States or any political subdivision thereof. Report immediately to Hunt County CSCD with this Order, and as directed thereafter. Pay costs of attomey in the amount of $\$$ $$ to the Hunt County Auditor, PO Box 1097, Greenville, TX 75403 on or before $$ , 20 $$ . [] [x] Appen in the Hunt County Court at Law No. 1 on $◻$ at $◻$ .m. and at all other times ordered by the Court. Any violation of the conditions herein shall be grounds for the autorpatie revocation of $m$ bond and the issuance of a warrant for the arrest of the Defendant. Bond in such case shall be depted pending review by the Court.

I have read and understood the above special conditions and understand that the Court will revoke my bond, order my arrest, and order a new bond hearing if the judge receives written notice concerning any violation of the above required conditions.

*16

*17

*18

LAW Offices of
JACK L. PARIS, JR., P.C.
ATTORNEY AT LAW
P.O. Box 8277
3101 Joe Ramsey Blvd., Suite 101
Greenville Texas 75404-8277

JACK L. PARIS, JR. March 2, 2015

RE: Cause No. CR1401075 (County Court at Law No. 1) The State v. Milton Edward Griggs - Appeal Our File No: 42454 Dear Jessica: Because of the crazy weather last week, what with the courthouse closing on Monday, the late opening on Tuesday, and the early closing on Friday, I just wanted to make sure that you had gotten word that you had been appointed with regard to the above-referenced case to handle the appeal. Enclosed herewith is a copy of the Notice of Appeal that was filed on February 19.

By way of background, let me tell you a few things. I was originally appointed on August 6, 2014 to handle the above-referenced case (failure to ID/fugitive), as well as Cause No. CR1301005 which is a DWLI enhanced Motion to Revoke and Cause No. CR 1301393 which was a harassment case. From the time that I first met with Mr. Griggs and continuously thereafter, Mr. Griggs acknowledged that he was guilty of violating his probation on the DWLI enhanced and that he was guilty of the failure to ID/fugitive; he denied being guilty of the harassment charge.

I was able to obtain a dismissal of the harassment charge. However, we were never able to work out anything with Jeff Kovach as to the other two cases that was satisfactory to Mr. Griggs.

On February 15, we appeared and, in effect, did an open plea on both the MTR and the failure to ID cases. Mr. Griggs' evidence and argument were both in the nature of mitigation issues and not guilt/innocence issues. Judge Linden was less than sympathetic, and assessed 100 days county jail on the MTR with 17 days' credit and assessed 300 days on the failure to ID with 16 days' credit.

*19 On February 19, we had a further hearing regarding the Motion for Work Release that I had filed in each case, but Judge Linden denied both Motions. In light of that, Mr. Griggs told me that he wanted to appeal the failure to ID case, and so we filed the Notice of Appeal and brought that to the Judge's attention, at which time, he appointed you to represent Mr. Griggs on appeal.

Part of the problem in the negotiation process and then in the sentencing process has to do with the fact that Mr. Griggs has two prior felony convictions and spent a pretty considerable amount of time in prison.

FYI - the State's best offer was 180 days on the MTR and 270 days on the failure to ID. Copies of both the final Judgments are enclosed herewith. If you need anything further from me, do not hesitate to let me know.

Kindest regards.

JLP/te Encs. as stated xc. Mr. Milton Edward Griggs C/O Hunt County Jail