Case Information
*1 IN THE TEXAS COURT OF CRIMINAL Appends, Cause NOV.
Clemmue wickware,
RECEIVED IN COURT OF CRIMINAL APPEALS
REIntor,
KOV 242015
THE SPECIAL PROSECUTION UNIT [SPU] OF 12th Judicial District Court of wailke County,
RESPONDENT,
PETITION FOR WOLT OF MAGNOMICS
TO THE HONORABLE Judge of SAIA COURT,
Comre's new Clemmie wickware, Relator Complaining of the special Prosecution UNIT [SPU] of the 12th Judicial District Court of wailke County, Texas and show this Honorable court that,
I.
REIator Clemmia wickware is presently inexercable in the High-sacquity- estelle unit [B-S-estelleunit. TEXAS Department of Criminal Justice - Correctional Institutional Division TACSCI-0] coming a so year sentence, maximum discharge date being August 2047. Applicant submitted a Criminal complaint with a temporary restoration order to clank of walker county and [SPU] the on August 20,2015 SEE: attachment copy
DJ- the walker County Clerk Mel Pupstes Deputy Reteun the filing with instruction to submitte to [SPU] which it was also file with see: attachment Court Letter.
DJ- Applicant SEEK Criminal changes and inspection [ERG] for voitation of the Civil Right of a Prisoner under 39.021 INUH and [a]
DJ- Applicant Physical handicap and SEEK action for violation of [EDA] American Disabilites act as and reckloss disregard to
*2 SAPely and handicap discrimination; and HAYnod condition is a daily Event," SAE Complaint.
The clerk MBI-Events Dibputy receive and rejected the Criminal Complaint on August 24th, 2015 the SSPIE have paid to Process Complaint File with them. WALKER Cawley is Located in Huntsville, Texas.
II. Relative, has File with SSPIE on August 20, 2015 and was receive at the same time 13th Judicial counthouse receive them and has cover over EME and [SQ] -days and the Criminal Act is still on going event and Court Bill to Provide number and the SSPIE. STATE has paid to (ANSWER) and has a notice of the wrong doing and no action has been taken on said Criminal Complaint with [TRQ]; Afthe the 13th Judicial actous and was given notice.
III.
On 7th clerk of 13th Judicial District Court has a duty under Criminal Law Purgeant Section Prisgator Right out 39.021-81040121 V.A.C.S AND TEXAS CUNSTITULONAL ACT I.SPRIAS—"IO.AUDIT" AND the U.S. CONSTITULOARI "E" "ROIETH AND B" "AMMEXID MEAT to PROTECT AND SSPIE" AND to INTERMEAN LOND: A PRISONER is subject to CAGOLON UNUSAL PUBLISHANT UNPlicated as wOIL As: vialation of Criminal Law to BNSWER Protection under PENal 25.07-25.078 and/or 61.083 Protection under on 14990 action Vialation H&; 483.075 to Act Promptly on this POJtLON AND PONWANd the same to the Criminal Court For Lnv Estigation and For disposition The Respondent Unwennated delay has prevented the Relative PRorm obtBuising a speedy Resolution and All Appropriate COnactive action," of SAld Criminal ComoIant with TEmppragy Abstains under: LIERAL-CUNSTAUDd
Relative, respectfully against the Court to Lideally Cunstain this wAT of mandamus Petitioner is unskilled and unstabded
*3 in Criminal and Civil Law. 10 Accordance with Fifth Circuit and 2upname Court's ruling under Hains of Anxiety, 404 U.S. 519,92 S.C. 894 [992] Three Facts, this said was should be literally Constated and not dismissed?
W.
WheRe forfe, PReMises: Considered, Relator despotfully prays that the Honorable Texas Court of Appeals issue on watt of mandamus to Compel the Distinct Court and 5 PUI dispose of the above-mentioned Pethen for Criminal Complaint with 5 PQ For corrective and 4 Pp Appriate action and lavobstigation.
IT IS 20 PRAYED,
14 P. 10
CARDIERATE OF SERVICE I HeRbBy Cbattly that a take and correct copy of this said wast of mandamus was on this day of JOYCONBA 2015 submitted through RACY-CYD Law Library for U.S. Postage to the Polloway Address:
Special Prosecution Unit 340 -5 H - 75 - North -Sulte-A Huntsville: Texas 71320
12th Judicial Distinct Cleak Mbl. Pikente Deputy 318 th Judicial Distinct 1100-UNIVERSITY AVR-SUTE-209 LONDWER County Courthouse Huntsville: Texas 71340 Court of Criminal Appoint of Texas P.O.BEX-12308 Capital Station
Austic: Texas 18711
Respectfully Explo mitted
*4 Clemmile Wickware, PlanityP, vZ. Kellie ward, math Cross, Tracy- Bailey, wayne Brewer, Bobby- vincent, K harit mott, Monk Eldon, Betty william, marco I Henker me- ver, Michelle Barksdale, min zeton ZAK, mulkey Lynn, Julye ernestine, Robertson mathaniel, chnistpher LACON, Kathy Hawkin, Bayan Haucock, John-Doesand/on Jane-Does Health seavice Division of Picals, John-Does safety of Picans,
Come now Clemmie Wickware! [TQEZ-CIÏ] Texas Dept of criminal JucticB-conectional 2 nstitution division NUmber No. #s5soil assign to High Security - Estelle Unit [H-S-Estelle] and is an Citizen of the United State over the age of Bill-vBars of age and sound mind an capable of making this AppiDavit De- spose and says, Employer of [TQEZ-CIÏ] Hbs-BEtelle Unit and/on [umTQUniter- sity of Texas medical Branch and on [TQCÏ] Health Service Division Clenaty violation of "STATE" and "PEDRAL" Law. And [TQEZ-CIÏ]" Health Service managed Health care. Policy as well as constitution- Al, LIBRAL CONSTRUED PlanityP. Respectfully Report this said Criminal complai-
*5 'What is wuskilled and untestored in Criminal or civil Law, and, this said complaint should be Lienally constnued, in accordance with the Fifth-circuit and Supreme Courts ruling under, Hanee's U.S. 884 N.A. 404 U.S. S19, 92 S.C. 594 P993). There Fore, This motion should be Lienally constnued and not dismisedo.
*6 P0-22 Employee General Rule of Conduct, P0-22-Rule: 8 Failure to Follow Proper safety Procedure P0-22-Rule: 10 Fabrication of Records P0-22-Rule: 13 Failure to obey a Proper Order From Authority P0-22-Rule: 20 violation of statutory Authority, Count order Rule, Regulation Policies P0-22-Rule: 28 Harassment Discrimination against Person of a Class P0-22-Rule: 22 Harassing Retaliation against Another P0-22-Rule: 28 mistreatment of offender P0-22-Rule: 32 -Destroying evidence of given false input motion P0-22-Rule: 41 Denial of uniform Access to Court P0-22-Rule: 46 Falsification Promotion Application As well as the offender Heath Service Plan-coatedional managed Heath care committhe adopted pursuant to section-SOI. 146 of Tex. As Coilversment Code Plan Heath care Management Between TOCS and the UTMB and Texas Tech University Heath law'science Center under connection Manage Heath care Committee, stand- and practice and policy, Responsible Heath Authority (Essential) Policies and Procedure Access to care / truths-system ofPender medical and Mental Elassification- Heath Service Policies/ Emergency Plan and Drills/medical Pass/ section- C -CARD and treatment Level of care/ continuity of care/ standing order/ Standing medical order/qualified medical/ daily hanging of complaint Special medical Program [Physical handicap/ Psychiatry Service] section-E Heath Record/medical record As well as section- SEN of Rehabilitation Act of 1993 (section-SO4) and 29 U.S.C. S 794 [2000] And American with disabilities Act 42 USC S 12101 - 273 [2008] "NO-qualified individual with a Disneilitie shall By Reason of such disability, should be excluded?
*7 Participation in an EC denied the BEneft tof scaWice Program or activities of a Public entity on Ee subject to dis-1. celmination By any such entilly [BOR] and the impact of operation of the facility; [A]-Due to on two-row and there wo handicap exist on unit. I have Been Repeatedly depribe Access to medical apot, Visitation, ReCIRATION, X-RAys, Ect] and discrimination and against with Access to neerention and deprive of all Access due to eEYat on Not workinG; [B]-Due to H-5-ostelle Unit fail to have handicap exity on Unit for Emergency evacuation for handicap, housing on two-row. me and a Clns of offendens Life are endAnger daily due to wo handicap exit [IE, Fira, asoun, turnado, flood, earthquate, Borme threat, Power outage, Ect] and ofpicial reckless disnegnd of safety, AD-OY. 87 ofpender housing assignment Critzain and procedure, COCS-CLIN RISK mMNAgerment DEpt Risk mANAgerment manual section-V-occ upational saryty. medical dept -evacuation plan. These only, a EteVator and in a emergency situation "AD-ONE" is suppost to use any thing. Etectoral moreless evacuation, E J-Due to applicant House withow node-handicap cell and deprive of Handicap -shower, hand nail, wall nail, sink nail No Floor gnip]on Floor reckless disnBgrad to all saryty, and discriminated against, [D]-Due to applicant Being deprive and discniminated against with Handicap (esscutal): and Force to wear an [Jumper] that Place him at direct saryty reek due to use of [candian-cautches] and/or an [wheelch iiia] and Jumper coutnold one complete Body movement 18 higher orat get hooks contnold the lowe. ea part 18 Lower part get hook it coutnold higher part. And discriminated against Room other handicap, deWing of essential Clothes of [elastic Boxer, Pants, shut Buttondown on zippea shift].
*8 [E]-OFFicial under false allege of uWkNow OF oficial and deprive- 1 ments of all DUE-process and violation of [DCl-CLQ] disciples inany procedure of IV. section V. special procedure for certain categories of offender Q. section IX of the (Physically HandICTP) and not only under false allege excessive punishment when [DCl-CLQ] provide no punishment should exceed over [QQ]-days, and, AD-O3.76 ofender disciplinary procedure [F]-fail to provide and enforce one-now-restriction and keep his H 3 -18 Restriction up to date, discrimination. against application
The official Jo e Astignment shall be based upon rational and objective criteria and in such a manner as to ensure that the safety, security, treatment and rehabilitation need of all offender are met. And lawful category and authority of [DCl]RISK management. Dept Risk Management Manual section-V-occupation. All safety, DS-F-3 medical department-eVacuation plan
DS-F-4 OFFender housing IV.-A. DS-A-17 Americans with Disabilities DS-A-1 TACJ-SAPEty Policy statement I DS-A-5 Responsibilities of [DCl-CLQ] Employer (A)-E) and, AD-O6.17 Health summary for Classification
ED-1D. 61 TACJ-SAPEty Policy officials is and have act within criminal competacy with theta Limits of Liability and Criminal Reeklossness and neliugence And malpractice and deliberate indifferent and to his medical and access to Health Service.
Official is a depriving applicant of flights not privilege and is direct violation of presence flight at 37.031 -(1)(A)(1)(a) V.A.C. 2 And Texas constitutional at-1 section 10 and 19 and another violation of the U.S. constitutions 4, 1h 6th 8th 8th and 1th amend ment to be free from cruel or unusual punishment infected.
Freedom from Retaliation, Life-Endruger ment, REEK of safety, and AFFIant SEEK Criminal charge File against All DePendants,
*9 Killif wond, woyne anewa, Bayan Hancock, Tracy (aniley BoğBy Vinedat, John DoE and on Jane DOR's [TQCJ] health service division Khari moth, P.A. Eldon Monk, Kathy Hawkins, Betty william, Mauco J. Henken meyra, Michelle Barksdale, M.D. ZEON JAE, Mulkey Lyng, Matt Grass, July Ernestine, M.D.Rodentson math- Babies John DOR's on Jane-dors sA Fety of Picual, Charistphra- LACAX Brought to Justice Eon the attachment APELONII Page [1] through [9] and recond with [TQCJ-CJ] reconds supported of said cause of actions and violation of the law releyent to his on her individual and on official capacities all deffendant have and is neting under color of state law during all time releyent to this Censminal Complaint Purthea: manie Complaint say that, mart Grass, kelliwood, BoğBy Vincent John-Dor/Save-De TION JAE Emplojess of [TQCJ-CJ] and may be found during the hours of G:OD AM to S:OO PM at the following Address: Administration building [TQCJ-CJ] P.O.Box-99
Hawtcuille, 7exas 99340 - and official(s), woyne anewa, Bayan Hancock, Tracy Bailey Khari mott, P.A. Monk Eldon, Betty willian, Maca J. HenkEa- meyra, Michelle Barksdale, M.D. July Ernestine, Mulkey Lyno, M.D. Rodentson mathawlet, John DoE and/on Jane DOR's safety, Charistpha LACAX Employes of [TQCJ-CJ] or [UTMA] and may be found at and during the hours of G:OO AM to G:OO PM at the following Address: Estellowit on [H-2-EslalC]Unit 264-F.M.-3478 Hawtcuille, 7exas 99320-3322 Plaintiff REASON POA AN TEmgDANy, ReStanly andon
*10 PINistIPREspectfully show the following, [A]-NO adequate REemedy at LAW; [A]-BEcNueB RECKless disncgand to SAFety And WEEglgONE And Haraad Rksk, Retalation, Cammal Limits of LiraBility, Bevial Access to medical, Violation of [BOR], Fraudulont Clnim And Records to CAray out dpprive must of Handicap (Essentai) And violation of all Rights to Quc-pnuces Protection of Discip innny action And ExcessivE Punishment And Rause of of Picial capacity and Palsd Record of medical, And, [A]-Action within"dEIEB Bnate in difference" And malpractice And wanton to bePlict of HnAm By sudden tnEmination of mounnt medication And medicalion wAnne that such should not be tnEminated suddenly And [B, A] tnEmination of m.a. and nicuologist specialist under under False Clnim of [Ellerige] Place mounnt Life-Endanger and fail to Provide Any treatment for muscle-spasm, Clowns Ect? [B] - Blocking Access to medical qunitified [m.a] and on special ist By Heath manager and [P.A] when objection Clcarly made to see a [P.A]? and nurse consplang to deny access to tnentment Rctilition for BxBricise of coniexences [E]-fail to KRep mounit medical record of H-S-I&; medical Restauction up to date and doprivement of Handicap housing Reckless disncgand to to mounat SAFety of handicap essential [Handicap showeR, Anils, Pluva gnip owE-How Rectuction, special medical Clothes Ect? [D]-Place applicant and a Class of offender Life-endanger due to "no-handicap" exit on two-how and discrimin ation against handicap AFFcinder. Failure to have handicap Exit on two now on the hold wilt, "B.E. No-Ey! [Pon PIRB Anson, turnndo Plood, EarthquatD, BomE thront, Poweroutage Ect] And Emingancy situation "no-ONd" is to use an Elevator and anything Electional.
*11 [E]-dapnivement of Handicap showendoily and neckless disoog- and to sAFity [no-Flade grup, hand nail, wall nail. And medical Pall to have handicap shower within facility within the medical infiamatly. 888 [F]-medical is and have act within fraudulent of promotion of application step-I Enicvance hind officials acting over the ofponder medical complaint within an Conspiracy of thela Liability and Participate and Position and use of an Eueren stamp[le,' step-I medical Enievance Program offer 10E of professional standards TACI-HEALTH SERVICES DIVISION] and Conspiring and allowing the DeLfepaste indifferBance, malpuncture, sA pely Harand, denial of medical act, to continue under Reckless disnegand to ofponder complaints, And fail to ensure Enievances,' [1]- acting within Delieprate indifferance to offend an Right to see a qualified medical. Personal and All oun A [E, B dion knowk and K. mott] to Black all rece. ss to movant wded of treatment, essential, ect, [2]- acting within Delieprate indifferance to offernder Access to qualified medical personnel under fraudulent promotion of [mental- state] and completely doing treatment and continue of treatment under take claim of ofponder psychologist hind movant [injection and/or chenoc-illesses] need of investigatious, Exaimination and Lawful record and testing And treatment. [3]-acting within Delieprate indifferance to offenders a Class mectical, ow due to a now medical nature result ing to Funtler, into Pannuce denial, mapractice and retalintion for exercise of access to count, grievance ect, [4]- acting within Delieprate indifferance with movant and Class handicap (essential) and discrimination retalintion, And aBase of Immediate and indeprintele harm in the aBeeNce of protection and/or preliminary instruction on [Trig],
*12 [3]-upon a Favorable Ruling No-Adverse effect will be Impected upon the dependants and/or officials. [4]-the inguuction and on preliminary inguuction on [re] will serve the interest of the public. [5]- the Plaintiff can prove to the courts though records contained by H-S-esterlto Unit Record Rept and medical, and graivance and [umt] Records, asd mewtnl Records, disciplinary record, and a class of Dependen Beny deprive of specific-medication handicap essential and complete denied treatmeat and cause to suffer daily and without protection or inguuction within this Criminal action immediate and interpretable harm will further come, Plaintiff is being deprive of adequate medical and subjected to malonnetice, denied complete access to qualified medical and nottalited agninst due to PAs: graivances and Place at risk of bann daily and denied continue of treatment under Pale Clains). [6]- through evidence of records of graivance, disciplinary, sick-call and abetest, and appropriate test of medical and within Houlsville Possession a Favorable Ruling will be given to Plaintiff in this instant Criminal complaint and inguuction and/or [re] Report that an Issue of an [re] preliminary and Permanent Innunction Punsuant to his Rights of: Inguuction, violation H-S-483,073 and/or protection under violation Pennl 2507356071 and/or Art 6.08 Protection order Phobietion ofPense cause By Bias and Prejudice, Retaliation Pennl 36,06 and Complaint Request an Issue of an [re] upon dependant or their agents to referin from or Ad minster, 2 [A]-reparin from violation of section-son of rehabiliation act of [973] (Section-son) and rehabilit at 1973, 29 usC 8794 [2008] and American with disabilitie act: 42 usc 812001 - 273
*13 [2006] No-qualified individual with Disabilities shall be reason of such disability, should be excluded from participation in or denied the benefit of service, Program or activities of a public entity or be subject to discrimination by any such entity [2007] and impact of operation of the facility? [1]- masual and Pracem mounit Life-endanger, safety and discrimination against him housing him on two-now that dose not have any handicap exit, on handicap emergency evacuation; [2]- and failure to update his H2-18 medical restriction-ONe-Ram restriction special housing handicap cell from october 21,2011 [3]- and depniving mounit of handicap essential of [hand nail, nail nail, handicap shower kit] [4]- and depniving and discrimination with his handicap (essential) of special Clothes two-tree [Shint, Print, Boxer]ect, and From; [5]- and from neckless disregard to safety due to use of an Jump on suit and denial handicap (essential) when operation use of [wheel chain, crutches, with/on ect] [A02] essential. [6]-reparin from housing may and all operators handicap on two now unless operation give consent wative of one-now test diction house [reprod of medical]; [8]-reparin, from depnive. may and all operators of [TDES-CIG] Arccplinary procedure and Process protection and Rights For operation of special procedure for center/categories of operation 14-section V. of D-section IX of [Physical Handicap/montal ect] [1]-reparin from (faborate) of second and computer with False Alloge of Aouse of Handicap (essential) to deny treatment [2]-reparin from retalation and discrimination against mounit with his handicap and neckless disregard to his safety, with special [E]-reparin, from use of Rubber stamp with By TACI-Health Service Division step-1 medical conference Program office of professional standard without, official action over the conference without signature title and name. [4]-reparin, from Cancel the object not and Lifility and
*14
ENdentity of Person and Participation (Fraudulot records): [D]-Administer; order that [E, A] Nud/or K.mott nermin From Blocking Access to qualified medical Personnal, [A]S] And to ensure all Access to medical For any nud all medical complaint; [H]-Administer up to date HS-IS-Prom october [A]IQ of handicap cell, order, [B]-that offerents Administer: An Handicap extts on two-now! For emergency evaculation; [E]-official Administeric handicap shower within medical Pability, [D]-Administer; handicap (essential) clothes For handicap special needs And safety Hazard [E]-Administers "handicap (essential) hand nails, handicap shuwer and Lnusful one-now-restriction due to no handicap exit extent; [F]-Grant avu other nelice as it may appear applicant is entitle too; I IS so Prayers, Respectfully Submitted Clemmue Wickware slide Unit Huntsville, Texas 77320-3322
EErtificate of Service
I Heaely centify that a two and contact copy of these Pracgoing Criminal Comolant with temporary restrains order was on this day of August 19,2015 was submitted through 1 Nidgent mail for Postage An mailing to the following address:
Shorter of walker County . Huntsville, Texas 77320 special Prosecutor Unit North, Suite-A Huntsville, Texas 77320
12th Judicial Distinct 278th Judicial Distinct 1100-University av2-suite-209 walker County Counthouse Hontsville, Texas 77340-11-
*15 AFFIDAVIT
STATE OF TEXAS County OF WAIKER
SWORN STATEMENT
By: Clemmie WICKWAR
I Clemmie WICKWAR
SSSODI I AM SOWd mINd ANd LAWPOI DutY INCRECEATED AT TOCS-CLQ TEXAS DEPT OF CRIMINAL JUSTICE EXERCITION AL INSTITUTIANI DIVISION AT THE H-S-PSTEllE UNIT 264-F. M-3478 HUNT- Sville, TEXAS 77340-ANd RECEPTFully REReEy STATE AS POLloWS,*
[2]-Applicant WAS ASCTign to H-S-PSTEllE ADMINISTRATION-SEGREETNIN [Ad- SEY] High SECURITY-STECLLE UNIT [H-S-PSTEIIE] UNIT WHEN UNIT OBEN LIP dUE to [HANDICAP-CELL] NOUSING that PRAGIDD Physical hANDICAP ESSENTAL FOR THE PHYSICAL NEEDS [HANDICAP-STOWER, hANDIAIL, WALL RAILS, SINK RAIL, EET] dUE to Alloge OF MEDICAL FACILITY.
[3]-Applicant is MEDICAL DIAGNOSIN OF PARTIAL PARAly 2E dUE to AN EXTENSIVE SPINAL-STENOSIS ON [HYPERARETIANA AND CLONUS] dUE to [LI-2, L2-3, L34, L4-5, L5-SL] AND MILD BULgING ANNUALS WITH MEderate CANGI the NEURAL FORMINA ARE ALSO NARROWED BRATES- ally PHYSICAP hANDICAP SINCE [L994] AND REQUER to USE [CANADIAN- CROTENES] FOR MODIIITY.
[4]-Applicant state medical HUAKER SUPPRIVICON BOREN VINCEST, MIA JULIER- EAKY AND ACT OVER A PIICANT MEDICAL REPERIODly AND A WARE OF his MEDICAL DIAGNOSIN AND H-S-PSTEIIE UNIT PACIITY AND LIMIT HANDICAP NOUSING AND THE H-S-PSTEIIE UNIT [HMO-ROH] NOT MAVE ANY hANDICAP EXIT. AND ISSUE MEDICAL ORGEN REPERIODly during their ASSIGN to the H-S-PSTEIIE UNIT AND NOW ACHING OVER [P.A]EDIAN MONK AND [P.A] EDEEAT WIIKINS AND AS AIIOWING, theM to CARIY, OUT out the POLloWING.
[5]-MALPRACTICE, BLACK OF ACCESS to gLAILPIED MEDICAL PRACONAL, BACK ACCESS to ASSISTIVE DISABILITY SERVICE [ABS], ORNINI SPEC- IFIC MEDICATION dUE TO A NOW MEDICAL WATWAY, ORNINI OF PIGHTS AMERICANS WITH DISABILITIE ACT [ABS], RECEIVES dUSRESPAED TO SAPEly, hAYRAD CONdition, ORNINI OF CUNTHIVE OF TREATMENT, ORNINI ACCESS to MEDICAL, AND ACT WITHIN CONSPIRACY TO HELP TO
*16 carrying out retalition and denial, inde penance and deliberate indi- pegnance to mownt and a Class of ofPender Right to be free from harm, lonesesans risk of Harm, hazard, safety and protection of all person and on handicap evacuation [BOR] (BOS) (essentant) violation of evacuation Plan, housing and daily essential need specific of Handicap enancy out secuity with due to interference with estalich odet to be ordens, [4]-allopricials are aware that [H-8-8stelle] Unit. Doze not have any hand- icdo exit that exist on the Unit two, roco and no handicap eme- rgenes evacuation for handicap ofPender and reckless place offend on LIPP endanger due to no exit for handicap [E.g. PIRD, arsuwiturnaty Flood/earth guate, Borme thrust, Power outage ect, [5]-official have number of offerdce house on two in a nowe handic- ap cell and Physical handicap and no specific sign of Handicap and they have one restriction going reckless disregard. [6]-official Khori mott and P.A. Edlow munk and P.A. Reeantson withan- iel, Juve-Embztine, BoBey Vincent And John Ooe And on JANE- Ques [FOCS]-Health Service Division, Michelle Eanksdale, mart Gsross Christphea L acoxe M.B. 2 EON 2AB, wavwe Brewery, Tracy Bnily, kEllie wand, Betty willom, has first hand Knowledge of mownt and Class ofPender Being wrongful have on two when in an Emergency situntion No ONE is to get on an [Elevator] and on any thing that is electoral ofpicials in aware of applicant medical need of modiity when use of Assistive device such as [Whe elchara, walker cautches ect] and [BOR] Bewerity of [1]-on February 04. 2015 mownt seek this rights to be free from Safety and to exit due to wrongfully house on two roco official Krmott and M.B. 2Eon 2AB reckless disregard request. [3]-ON January 15, 2004 applicant enough the 90 -handicapexit to M.B. BoBey Vincent attention and seek appropriate and up date of his H8-18-restriction and that the be connected with his one-now restoration due to reckless disncound by medical and official acting with in violation of [BOR]. See Cllic VINCE NO 200408 (0325.
*17 [3]-Further official Khani mott, Bobby Vincent, killi wAnd classification was put at notice of the disenamination and repeatedly deprived ment of access to medical, dental apps, visitation, decoration, X-ray ecf see: graEvanie no: 20010816748 sept 25,2005 And graEvanie no: 20010816736 . [4]-ON January 16,2015 And February 03,205 applicant sub milda request to K. mott [to no avail] And Classification. official Genial And BEligRnati-AndreRnance to handicap (essential) [5]-Official wayne Erawea, chustphea Lencox, Tracy Bailey, magnat, Capt John Does And on JanE-Does, Mott Gnoss in And have Act with in deliberato-Andi FREAneE to mowant And a class of offendera's medical By inter. training And officials Canning out deparivement of medical a By instruction And consp.ing with [B.A]Edion mowk And/on P.A. Robert wilkBws, M.D. 2 EON 2 AE. ANd on RoBentsun Mathaniel to deny mowant of Handicap essential under False and "none medical nature" to canny out netalintion And disclimination And medical have ANd is deorivina me of Handicap cell Base on a NONE- medical Nature and fail to Lavefully Estelish mu medical handicap H-Y-18-restriction. ANd show? [A]-ON october 07,2011 Lit. oAnBell suthow, Kathy Hawkins And Bryant Hancock use uwiscessany, And excessive. Force to move me to a Handicap - cell From a NONE-handicap cell due to medical order 2 Refuse due to ONE-ROU Restraction net Being. Enforce Houevra Bobby vincent, July e Ernestine And John DoE is a wane of my handicap needs And NONE-handicap cell Hazard to safety duc to [no-handrail, wallrail, sink-rail, handicap-shower], see: use of FoxO and graEvanie no: 2018082315 on about october 07,2011 medical fail to Lavefully Record this within his medical chant ANd Compliter And shows/also see? graEvanie no: 2011142703 [6]-THE medical fail to keep up with the restoration ANd Lavefully record my Handicap need For cell-handicap ANd of handicap shower official move, mowant to a NONE handicap cell about January 6, 2012 And magn D. Pankett nefuse to replace me within one due to NON-medical Nature.
*18 [C]-RECZ-CIGD DISCEPING any procedure provide; due-process protection and rights for officers special procedure for control Cateristics of officers. IV. Section V. of SEED-Section IX of (Physical Handicap, mental, act); THM any restriction on his or her mobility-or positionent of impaired officers should be deternine possible negative with medical consequences for given punishment; However it is wellestelish that procedural requirements for Death now and administration specialism [Act-SED] that no restriction should exceed a total of ninety 80 days; 1 P may; [1]-movout is not under any handicap or mobility restriction and no due-process was provide for the termination of handicap cell 1 P and/and. [2]-official and medical staff are doing him of handicaps[Section] and his handicap disability has not change and need fall to keep his H-S-IS restriction up to date SEE 2012/2013 No. 2013137044. [A]-applicant state: m.a. July 2 ANcstine and 2014 2AB is aware of my need of handicap (essential) of [Band-mail, wellfall, handicap show- ER ECT] SEE: 2012/2013 No. 2012024077 No. 2012014021 [6]-official K. Hawkins and B. Handock maliciously act within actalintion for movout exercise of 2012/2013 [BTC] and use P.A. T. Power and attempted to terminate movout mobility under false claims allay those of Cnuteers [Canadian Cnuteers] and Handock made metaliation Threats within pass SEE: 2012/2013 No. 2012079276 No. 20130795015 [A]-on July 27,2013 applicant seek handicap (essential) and housing [To NOWAil] [B]-on June 25, 2013 applicant seek his H-S-IS-medical restriction up date and Handicap [Essential] Handicap mail showe, well ect] and [BDB] being deprive Brought to Administration attention of the Disciplinary Punishment not exceeding [90 days 1 P may/SEE: 2012/2013 No. 20131169057 and No. 2013105699. [E]-on July 22-2014 movout submitted a sick-call' seeking handicap essential [Handicap showe, mail ect] and Physical Therapy,
*19 [D]-Applicant state May 28, 2008 M.O. Julye ernestine Givon of Ac. 1ot consent to use his inoaility as a forma of punish ment to tleminate his [Anndian Cautches] due to false claims of aause of Cautches. SEP: gnlevance no: 200815030?
D]-Applicant state of fivual K.mott, Boğay Vincent 18001 1AE. Ectly william, Gik voilliam, M.O. Julye ernestine, m.o. wathowel Regeatsan, Kathy Hawkins, P.A. Regeat wilkins, P.A. Edlow munk, marea J. HENkEre mavea. And LvNn Mubkey all is aware and have first hand knowledge of mounat Phyiscat Handicap and his records of HS-18 Restriction not being up date since october 2010 and the safety Haraad reckless disnegard despite arden of [Restriction for Transpantation of wibdichain Van and use of Candan Cautches] and medical fail to estelish Lawful handicap assignment?
[A]-Bearie-Pece Facility [B]-Single Level Facility [D]-special Housing with medical Live condition Handicap showery hand rail, wall rail, sink-rail Ecty Floon grip in shower; [E]-ONE-ROW GROUWd F100R Restriction of Heath classification summary and right to [BAR] and/or [BAS] (Essential) ect, see, gnlevance no: 201415501 and no: 2014094276 officials have allowed cecuaty to conhold offend or housing and reckless disnegard to offender as a class medical restaration And they are depniving offender with out their [consent] of medical treatment within a violation of state and federal Law.
QFivual interPANCE And BERIERNATO-INdIPPANCE, ANd Restalation:dis chtmination with offenden handicap (essential) under false claims of aause
[B]-Applicant state: medical staff have all act within re talation for mounat exercise of his right to [BTC. gnlevance ect, and allow security to issue unlawful restaration on offenden medical need at this H-2-estelle unit and reckless disnegard to all Phyiscat Handicap safety due to Handicap (essential) And special need under false claims of aause.
*20 [3]- Applicant receive [BHOB] Physical Handicap of Program [essenta] of now AKA assistive Disability service [ABS]; medical treatment of since [E997] until K.mott and Betty william act within deliberate indiffusance and nataliation, discrimination to movant and a class of operation right to special needs and reckless disregard to the safety Hazard; consistent with [ABS]-clothes essential of medical; [4]-on march 26, 2013 movant handicap clothes was removed by M.D. Robertson Nathansel of Buthon down on 21 pper shint, elastic waist Band Box and Paint and shint] sand atoms is usua to handicap orpcodes under special need due to Hazard could ion when use of medical device [i.e. wheelchna, crutches walker cand cet] due to the safety and Hazard condition of use of an [Jumpers] and [tie-up-Boxers]. [5]- 74 E [Jumpers] contaiold one hold complete body move ment and when get hobk on something or in wheelchair-wherek to the upper contaiold the bottom and bottom contaiold the upper movement aim on legs, neck, back eety Place handicap at risk of Harm and safety. [6]-movant has repeatedly been inguned due to the use of An [Jumpers suit] and each due to duBed raw by Jumpers when use of crutches and cause skin discoloration scale to his body and Fell down with gen of time since [5-24-2013] [6]-on may 24, 2013 movant had a medical appt with M.D. Getty will-: 1am Before the Appt Beggin this on seen me in a white zipper shint and got made and told orpicers to take this shint clearly act on nataliation for deeffective of [E 7 E] orpcodder (inlevance and to mistreat movant File grapvance nos 2013159085 [30 no minil official K.mott consptaced with the net; [5]-orpicint L.t. sutlow and sight John doe Threativg to use Punce 2 P shift was not given to them due to m.a. betty william taramination. m.a. getty william maliciously and cadistally aguce her authority to
*21
APPLISHALTC CONT PALL 7
craxy out retalintion and official k.mot and security Funthea dep aive movont of Handicap (essental) Afted this event with Betty william. see: gravence no: 20131573116
OPTicial completely dep aiva mounat of all Handicap (essential) to this day. Alloge that m. A. Roeettsun natthosid concell the order by B. PARKEr, under Palsb alloge of a euse of items, by unknon officials and no oue. Pracass Protocitoy, Funthea retalintion, [D]-medical staff; malicously and sadistically Place Pake necunds on res-gust that, I use my special needs items for [contamid and have use this alloge to elock all access to [AQS]-and K.mot. Miche lle Garksdale, Zgon zaf, mAreo J. Henkeameyera, mulkey Lymn, July D anestine, Robbatsun nathemiel, John 000 and Jane Doe safety, ch austp her Lncox, wanne Babewea, Cminan Rauchandern, Tracy Bailey, Robly william, and eobey vincent all neckless disnegand movant rights to be Pake Prami saryty Harad And hanm due to the wnongful tneamintion of his Handicap (essential) clothes, despite [A]-alloge is Palso and necunds are (farbacated) and even, If tave Puvishment Excessive And no Limitation ofricin have and is dicenaminting against movant and Place him: in danger of saryy daily, [B]-Funthea movant was dep aive of all oue. Pracess of [Tocj. Clu] tawom Disceplivay Procedure and Rights of OPPcndors special Pracedule Psa cabtan Catégorics, IV-section V of D-section IX of (Phyiscat Handicap) By false unknon of ficinl alloge of aeuze and record within computer by of ficials for John 000 on Jane Doe in retalintion see: gravence no: 2013158388 and no: 2013209678 No: 2013204605 No: 20131993116 [E]-on freenng 24, 2013, Jor 0 mo van't sub mited siekwall neoust for soecinl clother due to desinl [to no avall. [D]-on JUNE 05, 2013 August 03, 07, 21 of 2013 october 04, 07, of 2013 November 13, 2013 [to no avall [E]-on JANUAY 24, 2014 movant submittod siek-will nequest
*22 FOR special Elothes due to safety [Lo No Avall] [1]-Nurse manco J. Henkenneyen RN treaminated all sick-coll reguest for: [A]-hand nail, handicap shower, wall-nail oct. allcge that [not medically indicated] [B]-Physical Therapy request allcge that [not medically indicated] [C]-request for medical shoe allcge [not euthanizied at this time] [D]-request for handicap clothes allcge [not medically indicated] medical staff! 1. Henkenneyen is not a [P. A] or [nA] and medically denied access to medical and is a coyceistent malicious Pracific and Pattian. By him and Lynn mulk- ey through movant treatment, [F]-Furthengion June 06, 2014 movant submitted sick-coll to official michelle Brakdale for handicap essential [Lo No Avall] at [G]-ON November 04,2015 and April 07, 2014, April 22, 2014 movant submitted sick-coll to Michelle Brakdale [o No Avall] [H]-ON December 24, 2014, January 24, 2015 and march 24,2015 movant funtion seck handicap (essential) [o No Avall], and June 01,2015 [12]-or Picinl'smberge have Dinecl Knowledge and A Responsibility to expune of treatment HEAHh case management and appropriate medical and [BOR], [ADS], qriovances, request, tainge complaints, curtin ulu of treatment, access to medical and ensure lawful docu- mentation not within fraudulent claim and that ofend an specific or special medical need or all category of lawful man docent not of perial acculement and reckless disregard movant need For safety, Harand condition seE, qriovance no: 2014020055 no: 201402014 7. movant depriu of HANDICAP essential to this day. Also seE: qriovance no: 2014020271.
*23 OFFICIAL CONSEAL OF LIABILITY, PARTICIPATION, ENAUDISEMENT OF Application and I ndestity of Person Acts.
[13]—Applicant State, officials acting over T DCJ-CJA step-II have direct knowledge and action within due to fail to ensure grievance and willful with knowingly patentively reckless disregard violation of safety misinterpretment, hazard condition, responsibility, and use an RUERER stampin stand of name of officials acting over step-II Grievance as and when ask who act over individual Grievances from E E E through out the above grievances and November of, 2013, to this day for example,
[
[14]—
opfficials are acting under color of law and contrary to state and Federal Law and allowing violation to continue and is Person Allienter and responsible to his or her individual and official capacity as involved meant for supervision directive ensure and/or management of penal requirement and state and Federal Law as well as constitutional Law. John Does and on June 2005 offer 150% step-II medical Grievance Program official of process 1041 stated and T DCJ-Henth Services Diviso is and have covered their 2ndestity and PARTICIPATION AND ENAUDISENT OF the Grievance step-II application with a RUERER stamp and is acting under color of e eward rackless disregard of official training complaints, allowing them to continue violation clearly reflected, From 2013, to this day.
VERIFICATION
[15]—
I declare under penalty of perquy that foregoing is true and correct to the best of my knowledge and ability and I have need the allege and said act pursuant to 28 U.S.C.-SEC.-17 RC.P-132 through 132,003 2nd report of this STATEMENT ARRENVE QPHC-08-18-2015.
*24 Robyn Flowers District Clerk Walker County
August 25, 2015
Clemmie Wickware #555001 Estelle Unit 264 FM 3478 Huntsville, TX 77320
The District Clerk's office has received your paperwork regarding a Criminal Complaint with a Temporary Restraining Order. Should you wish to file a civil suit in the courts of Walker County, you must follow the rules outlined in Chapter 14-Texas Civil Practice and Remedies Code. If you would like to file a criminal complaint, the complaint should be filed with the Special Prosecution Unit (SPU). You can contact SPU at 340 SH 75 North, Suite A, Huntsville, Texas 77320. All documents received by this office are being returned to you at this time.
ROBYN FLOWERS, WALKER COUNTY DISTRICT CLERK BY: Mel Fuentes, DEPUTY,