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0€T03ER~?-2013 " ,

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MR. TDCCI:

I AM HGPING YOU HAVH FILED 303 AN INVESTIGATOR FOR MY CABES.
83 E$EED ?ICTURES 03 THB FRONT 03 THE HOUSE AT 153 HOLLIDAY PLUS
THE DRIVEWAY GF THE HOUSE AND ?ICTURBS 03 TH,E BACK 03 THH HQUSB
IN APARTMENT# 3 W8ICH IS A SMALLER HOUSE 83333 I ACTUALLY LIVED,
FQR CAU3F d 3597 AGG A3S AULT 8/ D3ADLY 83APOH, AND 3U3PO3NA THE
PLUMB3R HR. BARNES FROM 13b PRIORITY PLUMBIHG. “

18 CAUSE# CR-2293, FELGN IN POSSEBION 03 FIRF ARH, 83 83 33
AN INVESTIGATOR TD GET- TRAFFIC CITATIONS THAT OFFICER RAMOS ,
WROTE IN BR? WEEN THE ,HDURS 03 93 OOQM 333 io;OOpm, IT WILL PROVE
. 83 WAS NQT GGING NGRTH 08 FRESA BUT WERE WRITING CITATIGNS 30

ANQTHBR vEHchF BEFQRE THEY ser BEHIND 03 ON ran NIGHT 09 Nov 9
9, 201£, PLUS ANQTHER chATIom HE waowe MF 03 omnEn TRAFF c £[)3
swain me usgs savoy sum mg w \~,A=soea,A Ar.so.subpoa\@v¢ ‘_’Qum\\ OSIAS DC\\)e\r

83 NEED A MOTICN TQ QUASH INDICTMBNT, A HOTION 303 GASKIN
MATERIAL, A MOTION 303 BRADY MATERIAL, A MOTION 303 EVIDF HCE
_FAVORABLH TO DEFENDANT, A PRETRIAL HEARING MOTION'AND DIF COVERY
MOTIONS. I NEEB ¥OU TO SIGN 98 8¥ MEMORANHUM IN SHPPQRT 03 333
MOTIQN TQ SUPPREBS IN CAUSE§ CR~2293 FELGN IN ?03833108 FIREARM,
ATTACKING THE STOP SEARCH AND NEGLECT 03 DUTY PURF UAHT ARTICLE
2. 03 QF THE TEXA$ CGDE OF CRIMINAL PRQCFDURE, BECAHSE THE OFPICER
ON THB PASSENGF 3 SIDE DID NGT WRITE REPORT, DUE PRQCESS VIGLATIGN

83 NBED MOTION TO DISMISS INSUFFICIENT 3VIDENC3, A MOTIQN
TO DISCOVER THE CRIMINAL 33 QCORD 93 WITNEBS, A MGTIGN 303 GASKIN
:MATERIAL g A MQTION 303 BRADY MATERIAL, A MOTIGN 30 QUABH v
INDICTMENT, AND A MGTION TO SUPPRESS. I NEED YOU TQ BIGN 08
TQ MY MEMORANDUM IN SUPPQRT 03 THB MDTION TO SU?PRESS, ATTACKING
`THE RECKLESS DISREGARD OF TRUTH 18 SEARCH WARRANT AFFIDAVIT
IN CAU.3 33 CR~3597¢

wa HAVE wAIsTED 50 DAYS ALBBABY AND MY DEFENSE 15 BECQMING
IMPA;RED. z HAVE ALL oF THBQE ABOVE MQTIGNS QN FILH AL&BABY
PRQ sE, PLEASE vISIT ME 30 wz cAN coME To Aw AGREEMENT ow gow
83 ARE selma To FIGHT MY CASES.

PLHASE DGNT FDRGET ABQUT THE INVESTIGATOR¢

THANK YOU!!

y 33 ECT ULLY¥Y
, 101
l . MMM.:Q YC/

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3333 ' ' »

OCTOBER~l-IZ

DEAR HONORABLE JUDGE MELISA SKINNER:

I MET WITH MY»ATTORNEY JAMES V. TOCCI FOR THE FIRST TIME
AUGUST 3, 2012, HE TOLD ME HE WOULD VISIT ME 2 WEEKS FROM AUGUST
3, 2012, BUT HE NEVER SHOWED UP. MY NEXT COURT DATE WAS ON
SEPTEMBER 21, 2012, HE WASNT THERE AND I WAS RESET UNTIL
SEPTEMBER 25, 2012, HE SHOWED UP AND I EXPRESSED MY CONCERNS
ABOUT MY DEFENSE BEING IMPAIRED BECAUSE I NEED AN INYESTIGATOR
TO TAKE PICTURES OF ALLEGED CRIME SCENB, LOCATE 2 WITNESSES
AND ALSO GET SOME KIND OF RECORD OF TRAFFIC CITATIONS WRITTEN
IN ANOTHER CAUSE. I HAVE 2 ALLEGED FELONY.OFFENSES IN 290th
DISTQ;QT COURT, CAUSE# CR-2293, CR 3597, l NEED WITNESSSES
SUbP§§S§§§ IN BOTH CASES. l KNOW MR. TOCCI IS A GOOD ATTORNEY
HE MAY BE REALLY BUSY WITH ®THBR CLIENTS. NOW MY COURT DATE
IS SET FOR NOVEMBER 9th, 2012, I NEED THE INVESTIGATOR TO BE
WORKING NOW BECAUSE M¥ INNOCENCE-IS BECOMING IMPAIRED, WE HAVE
WASTED 50 or 60 DAYS AND WHEN NOVEMBER 9th GETS HERE 100 OR
MORE¢ I HAVE MOTIONS ON FILE PRO SE AND MEMORANDUMS I NEED MY
ATTORNEY TO SIGN ON THEM. AT THIS POINT HE HAS ONLY FILED 1
MOTION AND I CANNOT¢GO TO TRIAL WITHOUT CERTAIN MOTIONS BECAUSE

I WILL HAVE NOTHING TO PRESERVE ERROR IN THE EVENT OF APPEAL.

THANK IQU FOR BOTH YOUR TIME AND EFFORT!!

RESPECTFULLY:

w \05>%7~

RAYMOND DANIELS SID# 358196
OCTOBER-1*12

 
  
 

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!*- )C\~~IB

THE sTATE 0F TEXAS` IN THE DISTRICT coURT
- VS ~ 290th JUDICIAL DISTRICT
RAYMOND DANIELS JR. BEXAR COUNTY TEXAS

TO THE HONORABLE JUDGE OF SAID COURT:

MY NAME IS RAYMOND DANIELS JR ,THIS is my second letter to you_
regarding my concern of my defense becoming impaired,my court
dates have been AUGUST 3rd 2012 ,september let 2012 september
25 2012,NOVEMBER 9th 2012,and i have a court date set now for
JANUARY 25th 2013,at this point my attorney JAMES V TOCCI HAS
yet to a§Kthe court for an investigator for boud\of my criminal
cases cause no.2011cr2293, CAUSENOCR 3597,ihave witnesses that
need to be subpeonaed in both cases also in causenocr2293 i
need pictures of intersection and record of previous traffic
citation written by officer felipe ramos ,incausenocr3597g§

in causenocr3597 i need pictures of residents at 158 halliday
front house and back house where i actually live.

 
    

    

l lo ls thankyou

- IMELDA FiC-UERO%, '

` fog §CE
§:;.%.::; NoTARY PuBLlc ‘/l;/
- ,.-'a,.-‘ sTATE oF TEXAS

tg-.

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z¢;v;§@i San Antonlo °"@"S°Cas°#
~* § SAPD11281979
Po| lee Offense Descr|ptlon
FELON POSS F|REARM
Date l Tlme Occured
11/9/11 9:51 pm to 11/9/11 9:51 pm

Offense Locatlon C|ty ` State le

3600 S. PRESA SAN ANTON|O TX

Report|ng Off|cer Name Badg<av

RAMOS, FEL|PE 0206

‘ N_'arjn'§ 1 ` nos Age

DAN!ELS, RAYMOND ` v 05/02/1965 46
_v _ t 02an Aqdre§§: 158 HALL|DAY AVE SAN ANTON|O TX 78210

Name DOB Age

ROSAS, JUAN 07/07/1964 47

Name DOB' Age

Year . Nlake ' Mode|

1995 CHEV BER

-
Type Descrlptlon Brand Mode| Co|or

 

 

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Page 1 of 2

  

   
  
 

 

1113   " . "`)<k;l@:l~li')“\

NARRAT|VE

  

On the listed date and time I was on patrol with (Wl). (Wl) and I were both in a marked police
vehicle while in full police uniform. We were traveling north on S. Presa when the listed vehicle darted

out from Halliday (westbound) and made a v_eg;g_gi_§l;;ight turg_ (north) onto s. Presa. The vehicle .
completely w the posted stop sign at the listed intersection. I had to slam on my brakes to avoid

colliding with the suspect vehicle. The vehicle also had a light dangling from its reaiptha_tT/v;§__`_'L
covering the lettering of the rear license plate. Due to the traffic violations we activa ed our overhead lights

and conducted a traffic stop of the vehicle at the listed location. As (Wl') and I walked up to the vehicle,

(Wl) approached from the passenger side while I approached f_rom the'drivers. As I made contact with the

driver (SP1) I noticed he appeared to be visibly nervous. Whi|e I was speaking to the (SP1) I noticed the

passenger (AP1) was concealing'l_iis right hand into his open jacket. The (AP1) was asked to remove his

'~ hands and to place them on his lap for our safety. I asked the (AP1) for a form of ID and he advised me
"_'t_hat_`__ he did not have any. The (AP1) then began to nervously dig into his pockets after he had already

e_d me that he had no form of ID. As the (AP1) was moving around and digging in his pockets I
noticed he had nis left arm frm|y pressed up against his left side. His left arm was not moving as if he was
event something flom falling out 'At thls~'~aint (‘.".12 an -."'l.'-B~‘ had arrived on scene to nrn\/ide.

 
       

1 " lc ver. Due to the way (AP1) was concealing his hand and the way he had his arm pressed on his side,
_» ` `_(AP1) was asked to exit the vehicle to be frisked for weapons for our safety. As soon as (AP1) exited (W1)
" began to frisk the (AP1) and immediately felt (E) inside the (AP1)'s right jacket pocket The (W)' s quickly

took (AP1) into custody without incident. The (AP1) was searched and then placed in our patrol car under
arrest for felon possessing i"irearm. The (AP1) also had money on him in small stacks which is consistent
with those involved in the illegal sale of narcotics. The (AP1)'s phone would not stop ringing and it had
numerous messages for people asking for narcotics. The (SP1) was cited for the traffic violations and
released. The (AP1) was transported to 401 S. Frio for booking and the (E) was placed in the SAPD property
room.

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