Case Information

*1 IN THE FIRST DISTRICT CART OF APPEALS IN HOUSTON, TEKAS

William M. Jones VS. The State of TeWa

Fiest Car† of APPEALS CASE NO: 1387546 † 1387547 Appellate No: 01-14-01033 † 01-14-01033

MOTION TO AMEND MOTION FOR APPOINTMENT OF NEW APPELLIATE CONSEL

To The Honorable Judge of Said Car†:

comes now William M. Jones the Appellant in the above Captioned and numbered cause respectfully moves this car† for an order to Amend Motion for Appointment of New Appellate Counsel and in support of this Motion to Amend the Appellant will show unto this car† As follows:

The Appellant is presently represented in this Cause by ANN LEE MOSELY T.B.C. 90001927 whom the Car† Appointed to represent the Appellant on the month of December, 2014.

In regards to Appellate Counsel not properly filing a timely and procedural motion for new trial. There has been pertinent Substantial Evidence that has been hindered from placement into the Records. Such as:

*2 (1) Material evidence pertaining to consent being involuntarily was taken which trial counsel should have objected to. (2.) Crime Victims Compensation documents showing Appellant was already excluded from incident due to payment of 55,000 dollars - 50,000 dollars went to doctor's fees and 5,000 dollars went to Appellant for workmen Compensation. Appellant was currently working for Core-PRO Systems "A Cras $\frac{1}{2}$ OIL Company. (3.) Witnesses which was never called Nor Received Affidavits from. shows Appellant lived in the area, Also Sture employee of "family Dollar" statement(s) about clothing bond across the street from Where crime took place stays full oral picked through at times. Itsthere for Donations. (4.) Expert Witnesses - Doctor's/More's Statement - proving the condition Appellant was in prevented him from fleeing the scene of the crime. Hospital reports, X-Roys showing where Appellant sustained injuries. (5.) Clear and Convincing evidence that '567'gun used by Victim, in an attempt to shoot perpetrator, was withheld from the sight of the jury upon request by defense counsel. (6.) Information such as policies and procedures of (HARD) Haus ton Police Department regarding Crime Scene Investigation policies and procedures. Due to Investigator Not processing car into evidence, Nor Investigating Appellants statement as being a victim of a shooting. These are referent and needed issues in Arguing and properly preserving error, Further, which mids to show due diligence!

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III Appellant was not able to properly prepare Argument Nor Add 'new' hard evidence into the records, due to Appellat Cansel's failure to timely file motion for New trial.

IV The court should Amend motion for Appointment of New Appellate Cansel and Grant Said motion for new Appellate Cansel that Appellant may be assured reasonable effective assistance of Appellate Cansel that he is entitled to, SEE Texas Constitution Act 1316 and U.S. Constitution, Sixth Amendment.

PRAVER

Wherefer premises Considered, Appellant pays that this Carthamend motion to appoint new Appellate Cansel. Respectfully submitted this the 18th day of June 2015

William M. JoEs

I William M. JoEs, 100th 1971-347 from Tees Department of corrections being presently incarcerated in tetas Department of corrections Mark W. Stiles Unit, Jefferson Cunty, tees, ded. under penalty of perjury that the foregoing is true and correct.

Executed on June 18th, 2015

*4 Certificate of Service

I hereby certify that a teve and correct copy of the foregoing Motion to Amend Motion to Appant New Appellate Cansel has been Served by placing the Same in the United States Moil first class addressed to:

First District Curt of Appent's Sol Fanninst. Husdon, Texas 77002

ON this 18th day of June 2015

William M. Jones 10/19/2015

*5 ORDER Be it remembered that on this day of 2.015 come to be heard the Appellants motion to Amend. Motion to Appoint new Appellate Cassel.

After due consideration of Said Motion it is determine that it should be granted and it is hereby ordered.

It is so ordered Adjudged and Deemed on this day of 2015

Granted Desired

Presiding Judge

*6 First District Court of Appeals Office of the Clerk Sol Tanin ST. Huskin Texas 77002

RE: Filing Appellant Motion to Amend Motion to Appoint New Appellate Cantef. in connection to Cause ND. 1387547 and 1387546

Dear Clerk: Please file Appellant Motion to Amend Motion to Appoint New Appellant Cantef in the appropriate manner. Please refer any rulings and orders to the Appellant at the Address listed below

Respectfully, William M. Jones TDC3 1971347 Mark M. Stiles Unit 3060 EM. 3514 Beaumont, Tt 77705 Pro-SE

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