Case Information
*1 CAUSE NOS. 01-13-00415-CR;01-13-00416-CR;01-13-00417-CR
IN THE TEXAS COURT OF APPEALS FIRST JUDICIAL DISTRICT HOUSTON, TEXAS
FILLD IN 1ST COURT OF APPEALS ROOSTON TEXAS
V.S.
THE STATE OF TEXAS Appelle
MOTION FOR APPOINTMENT OF COUNSEL
To THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, JOYIER NOEI CAMPOS, the appellant, pro se, and respectfully moves this Honorable Court pursuant to the Texas Code of Criminal Procedures 44.1.051 (d)(2)(4) to appoint counsel to represent him in this above entitled action. The appellant will show this Honorable Court as follows:
*2 I.
Appellant was convicted of three separate accounts of aggravated sexual assaults of a child. (Cause Nos. 1308988, 1328806, 1328807) Appellant was sentenced to sixty-eight (68) years in prison.
II.
Appellant filed a timely appeal with the First Court of Appeals and the Court affirmed. Appellant's conviction on January 13, 2015. Appellant filed a Motion for Rehearing and a Motion for En Banc Reconsideration on February 2, 2015 and both motions were denied on February 19, 2015.
III.
Appellant filed a Petition for Discretionary Review with the Texas Court of Criminal Appeals on April 22, 2015. The Court of Criminal Appeals remanded the case back to the Court of Appeals for further analysis on July 29, 2015.
IV.
Appellant filed for one (1) extension of time to file a supplemental brief and was given till November 2, 2015 to file a supplemental brief with the First Court of Appeals on the remaining issue(s) on remand.
*3
.
The Appellant has no funds to retain cansed and has been proceeding in forma pauperis status throughout the previous legal actions. Appellant request representation of counsel on remand because a pertinent question of law has been raised. And in the interest of justice, being that Appellant is layman and cannot quite litigate such question of law, an attorney should be appointed to bring such betore said Court.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully proys that this Honorable Court grants Appellant's Request For Appointment of Counsel.
RESPECTFULLY SUBMITTED,
Q. C. C.
3.2.
*4 I, Javier Noel Campos, do hereby certify that a true and correct copy of the above and foregoing Motion, has been forwarded by U.S. Mail, to the State Prosecuting Attorney, Ro. Box 12409, Austin, Texas 78711.
Signed this 1 day of October 2015.
Danzas
Javier Noel Campos *1894-18 Appellant, pro se
INMATE OATH/DECLARATION
I, Javier Noel Campos, being presently incarcerated in the Mark Stiles Unit of the Texas Department of Criminal Justice in Beaumont, Texas, Jefferson County, Texas, do verify and declare under penalty of perjury that the foregoing statements are true and correct. Executed on this 1 day of October 2015.
*5 October 1,2015 Christopher A. Prine Clerk First Const of Appeals 301 Fannin Street Houston, Texas 77002 RE: Javier Noel Campos vs. The State of Texas Cause Nos. 01-13-00415-CR;01-13-00416-CR;01-13-00417-CR Dear Clerk: Please find enclosed petitioner's Motion For Appointment of Counsel. Please File it and bring it to the attention of the Court. I also ask that you notify me of the Court's ruling on same said Motion.
In addition, please dote-stamp this letter and return to me at the address below.
Thank you in advance for all your time and attention in this matter and I anticipate hearing from you.
Respectfully, J. Campos
Javier Noel Campos #1894473 Mark Stiles Unit 3060 FM 3514 Beaumont, Texas 77705
*6