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Bailey, Paul Clarence
WR-80,640-02
Tex. App.
Sep 29, 2015
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Case Information

*1 Abel Acosta, Court Clerk Court of Criminal Appeals PO Box 12308 Room 106 rae~rcn\\ HER n~n Capital Station \fll YtbU W lf:l1,.dl UU~ Austin TX 78711 ' COURT OF CRIMINAL APJPEALS SEP 2 9 2015 September 24, 2015 Paul Clarence Bailey

Ex-Parte

RE: 366th District Court, Collin County, Case #W-366-81879-09-HC, incomplete trial court record Dear Court Clerk

I am notifying you that I have not received any notice concerning this court having received the trial court's submitted Application of Writ of Habeas Corpus, with the State's Response attached pursuant to the provisions of Articles 11.07 ofthe Texas Code of Criminal Procedure Ex-Parte 418 SW 2d 824 826, Texas Criminal Appeals 1967.

The record the trial court transmitted to the Appellate Court is incomplete and defective and was forwarded prematurely. As you know, such constitutes an act requiring the application to be remanded back to the trial court (366 [1] h District Court in Collin County) to allow the trial judge to complete the record by holding an evidentiary hearing resolving the issues involved in Defendant's objections ( Objection to Submission of Affidavit Pursuant to Supreme Court Ruling in Holmes v South Carolina, 126 S. Ct. 1727 (2006); - Motion to Set Aside and Vacate Void and Default Judgement(s)).

Please instruct the Trial court appropriately in this matter so as not to hold the Defendant's Application in Obeyance any longer. Since an Obeyance has obviously already transpired, now exceeding the 90 day period, please request these issues be resolved forthwith in order to deflect any further deliberate indifference towards this Defendant and forbade any further illegal incarceration.

Please be aware that the Defendant is especially cognizant of the 366 [1] h District Court's propensity to spin their judicial merry-go-round and that this document effectuates no need for a Mandamus to follow ... excluding perhaps one filed in the court of public opinion.

In addition, I would like to call your attention to the fact that the PDF files for the last two motions I filed with this court will not open. I have concerns that this may constitute further obstruction of justice since these documents are part of the public record.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully Submitted

PAUL CLARENCE BAILEY, Pro Se

TDCJ #1833504

James Lynaugh Unit

1098 South Highway 203 7

Fort Stockton, TX 79735

By:~ . ._ .

Paul Clarence Bailey, Pro Se

Date 9/Jqf-r

CERTIFICATE OF SERVICE I certify that a correct copy of this document has been forwarded to Counsel , m accordance with Federal Rules of Civil Procedure on this J!f- day of $e...pf , 2015 as follows . •

Via U.S.P.S Certified Delivery .• __ .---"'-""'--'--

Court of Criminal Appeals P.O. Box 12308

Austin, Texas 78711 . . -"'---- --- -- -- - . - -:'llloooi ....... \.,..r·' - -o---...,_.....,___ Collin County District Attorney Greg Willis

2100 Bloomdale Rd Suite 100

McKinney, TX 75071

Case Details

Case Name: Bailey, Paul Clarence
Court Name: Court of Appeals of Texas
Date Published: Sep 29, 2015
Docket Number: WR-80,640-02
Court Abbreviation: Tex. App.
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