mm -0.:
November 221 2015 L’xCA ) \

,

Valentin Moreno, Jr.
788216, Robertson Unit
Abel Acosta, Clerk 12071 FM 3522
GJni.oECtmun£.Agg§ds . Abilene, Texas 79601
P.O. Box 12308 `
chpitoal station
Austin, Texas 787ll

Re: Writ No. 49/474-05; Ex parte Valentin Moreno, Jr.

Dear Mr. Acosta:

Enclosed you will find Applicant's Amendments To Application For Writ Of Habeas
Corpus with Appendix - A. All to be filed in the above mentioned cause and
brought to the attention of the Court, as time permits.

Also enclosed, is a self-addressed envelope with postage pre-paid. Can you please
send me a stampted filed copy of this cover letter, for my records.

May you and your staff have a Blessed Thanksgiving. Thank you for your time,
attention and assistance.

 

Respectfully,
MW%;Z/_/ d 2 . RECEIVEDIN
/ /L%L¢WQ COURT oF cliN/\LAPPEALS

ND‘J 30 2015

cc: file ` Abe' Acggta. C|Srk

IN THE
COURT OF CRIMINAL APPEALS
AUSTIN/ TEXAS

Ex parte §
Valentin Moreno, Jr. § Writ No. 49,474-05
Applicant §

APPLICANT'S AMENDMENTS TO
APPLICATION FOR WRIT OF HABEAS OORPUS

 

 

TO THE MOST HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW, Valentin Moreno, Jr., Applicant, Pro Se in the above referenced Case
and respectfully files, Applicant's Amendments To Application For Writ of Habeas

Corpus. In support thereof, Applicant would present the following:

I.
JURISDICTION

This most Honorable Court poses exclusive habeas corpus jurisdiction over the
parties and subject-matter/ herein, pursuant to Chapter ll in the Texas Code of

Criminal Procedure Ann. (Vernon 2015).

II.
STATEMENT OF CURRENT FACTS

 

l. Applicant filed a successive writ of habeas corpus application, on June 151
2015. Challenging a jury's verdict of guilty for Capital Murder.

2. The Attorney representing the State, filed the State's Original Response
and Answer, on July 8, 2015.

3. The Trial Court adopted the State's proposed Findings of Fact, Conclusions
of Law, Recommendation and Order, on July 20, 2015.

4. Applicant's successive application, was presented to this Honorable Court,
on September 22, 2015.

5. Applicant filed, Applicant's Motion For Leave And To Stop Writ of Habeas
Corpus Review. This Honorable Court granted said motion, on November 51

2015, granting Applicant (30) days to amend his application.

Page l.

III.
AMENDMENTS

Attached hereto, is an actual application for writ of habeas corpus form/
with Applicant's Ammendments. Applicant reasserts all claims asserted within
the original application.

Applicant has amended Ground Number One (A) and (C), and added Ground Number
Five. Pursuant to what is already argued in Ground Number One (A), Applicant has
added, a claim that he has presented credible scientific evidence, that oxdladdis
the scientific evidence relied on by the State at his trial. Said claim, submitted
under the provisions set forth by new Article ll.O73(a)(2) of the Texas Code of
Criminal Procedure. [See; Appendix - A, attached hereto.]

Additionally, Pursuant to Ground Number One (C), Applicant has added a claim/
alleging the prosecution team influenced and tainted witness Yvonne Gonzales' in-
court-identification of the applicant, with prejudicially suggestive feedback and'
post event information.

Finally, Applicant has added Ground Number Five, submitting an independant
claim under Article ll.O73 of the Texas Code of Criminal Procedure. Therein, the
Applicant alleges, that he has presented credible scientific evidence, that

"contradicts the scientific evidence relied on by the State at his trial".

IV.
Based on these amendments/ Applicant respectfully requests for an evidentiary

hearing.
PRAYER

WHEREFORE, PREMISES CONSIDERED, Applicant respectfully prays that this honorable

Court grant, any and all relief deemed proper and just.

Signed on this ;Q§Q{day of 440/@n44§@/ , 2015.

Respectfully Submitted/

Valentin Moreno, Jr., 788216
Applicant - Pro Se

Robertson Unit

12071 FM 3522

Abilene, Texas 79601

Page 2.

VERIFICATION

y

I, Valentin Moreno, Jr., hereby verify, that the contents and statements made

herein are true and correct, and offered in good faith/ and made under the

penalty of perjury.

Signed on thisgid day of M¢g£& / 2015 Q/
Valentin Moreno, Jr.
Applicant - Pro Se

CERTIFICATE OF SERVICE

I, Valentin Moreno, Jr., hereby certify, that the original copy of Applicant's
Amendments To Application For Writ Of Habeas Corpus with Appendix, was sent by
U.S. certified mail, to the Clerk of the Court of Criminal Appeals. Additionally,

notice of said filing, was sent to the attorney representing the State, via lst

Class U.S. mail.
Done On this & 0/ day of éédg/»ég/ , 2015.
Q/éé,/_/g;%%&

Valentin Moreno, Jr.

Page 3.

APPENDIx_-_A

[Appendix - A, Is An Application Form
For A Writ Of Habeas Corpus, Applicant's
Amendments To His Application Are Found
Therein.]

Ca`s"e No
(.The Clerk ofthe convicting court will f' 11 this line m )

1111 1111:<:01)111~ GFCRIMNALAPP§ALSOF TEXA§
APPLICATION FOR A W.Rl"l` OF HABEAS CORPUS

SEEKING RELIEF FROM FINAL FELONY CONVIC'I`ION
_UNDE€R CODF»;. OF C_RI’VIIN.AL PROC:EDURE§ ARTICLE ll~l 07

 

NAME Valentin Moreno, Jr.

DATE oF B,IRT_H:' JulY 19' 1976

 

RLAC.E'O'F CONFINEMENT:; French M. Robertso_n Unit

11)<:;1‘-1:11) NUM§ER=» .....W.__.... 4§»111'):§1)11111:11 ~

(I). Thi§:;appliea`tidn<.con'cerns"(check all that apply):-

Ki a eunvi¢:tibn; .C] parole
t\ a s¢n,tévee' 1:1 mandatoryZ'siu;;e::vs`si`dn 1
EI time»:creditl El vout`-,dfét'i`me appeal 01", petition .for`

discretionary/review-

(2)_ What district c`oiirt entered the judgment "0f the conviction you Want relief frdm?_
' (_Include the court number and county. )

332nd District Court, County of Hidalgo

 

(3) Wh`at W'_`aS the caséflix'mib"'e`r in the`:tr"ialycolil‘t?

CR-0517-96-F

 

(4) What:\yas the name'>'o'f"the trial j`u_dge?

Mario E. Ramirez, Jr.

 

Hfiec'tiv¢; Januan) 11.1120141 1

lRev; 011/1 4/1121j

(s): wereyi»iu represented'.by:_couns¢i? If/yes,pwvide_¢’v‘e_.aumey»"s;nme:

Ricard B. Gould and Norman E. McInniS

 

(;.6); What was'~the detectth fhe"jludgmenf-was enterei_i“?l-

March 31 1996

 

(.'z). Fo'r: what affevs~e:;wer:e;you convicted add_.wha::wa's cna sentenc1?1 1

Capital Murder - Capital Life'Sentence

`(.8).1E iit-you were senten;ced.:on more:than 01111111111111' of¢an .ind`ic;tm§nt:i`n the,same court atf
~the. sameftime,_ what.~counts'were;you convicted of.andawhat--was the sentenee?ih~each_
.¢011'!1’1¢,?1 ` §

N/A

 

 

('~9)' Whja't was1thé plea you entered?` (Che¢l'<z,ohe.).

` E} guilty-open~_p'lea. l:}' guilty-plea bargain l
110¢. guilty fl nolo C‘onteizd€rélnb“cii`lites`tf`

`If;:you ehte:‘ed different pleas to'c`c`)uh'tS-`in a"_mul`ti~co.unt indictment, plea$_e:explai`n:

 

 

'(10) "Wha`t kind of trial.d`id ygu;_hav`e?

53 no‘ jury 'IZ}` _j`\iry.foi;gui_lt and punishment
111 jury for guil!z<j.`udg'e for‘Punis_hweint

Rev». 0_1:/1_»4,/-1142

 

1111

(_1'}2)~

11»3)»

(514)

'§Did you testifyat‘ trial? I'flyes_=,;at whatr'phas'e df‘the:t'r`:ial didé§¥ou"tg:§tify:?

No.

 

El`),i'd yuu' app:eal_dfrom tuejuagmen't,,of convi;c'cion’?;

3 yes 133 n'o_

'If you did:app_ea'!~,; answer the-following .questiqn§:

1(_1§.5)= What»courtof"app'éa`l§_ did`f;you;appeai to_?f _l§_T_H__<S@_l.lM,Apneala___».,.__

(B_) -What was the ca§e number~? 13_97`00335_CR

 

(IG) Wer,_e'y<)u' represented‘fby»ciouns§l€on.»appea,l? I..f: yes,, providf,etllie=att¢>irney'§
namer ` ’ ` ‘

 

Mark_NAlexander _, _

(Dj Wha`t:was thedecis'i`on and the'~date pf;the.dg¢i:sion»?j » Af_f§m€d

~Did 1011 file a'»peffifion~for discretionaryrre§iew‘i'né'the_ Com>o_f Criminal;-Appeag$?;

@ Y`¢~s 13 nfl

'1`f,,y,c»11v did tire a petition far discretionin 'réviéw',¢`.answer the:fonm§ving questions:,

(A,')» What-was‘fh.e1~case number?- ; N/A

"(Bj 'What,'was ihe,1d'é'cisi_ozi and`:thj@qa_cjej ufthe.i‘decision"?' ~ refused

`Hav'e yo'\'j previously filed an application for a writ of habeas corpus `undér` chlé

11.0.7 of the Texas Code of Criminal Procedure challenging this convcctwn"

`l, yes ljs .n"o»

lf yca answered yes§ answé`i'=~thé fallowing q,uestions::

('A‘-) What was .t`he Coqrjt`ofi.Cr'iminal Appe'als’ writ number? »WR:QMZQ;QL__
3

Rev. 01/"'14-/~14

 

(’15)1

§(16)

(B)` ‘What:was>the decision and.;t"hé;.:da`te, df:the;d_'ecisi'¢")'n?;

Dismissed

 

'(`C.), P.leasefi`d¢niify:fh§ reason that the current claimsi‘we.r,e nqt.;_pres'§nted and could

’.not have been presented on your previous;~application.-

Note: The foregoing application1 is only an amended version of an

 

application already before this Court. On 11/05/15/ this Court

granted (30) days to amend the application.

 

 

Do you currently have any petltmn ori appeal pending m any other state erl federal
court?

251 §yes 'L';l= '_no.
'If‘yi)u:answeredjyes, please@:proyid"ef`t_hej_nam'e_j of;the“ court and thei~',ic__`as'einu'nilier;

As stated above, there is currently an application before this Court.

 

‘I"f"y'ou are presenting a'* claim fortinie*credit, "hav.el,.yo[uéx_h`austed.*yeur g
administrative remedies by presenting your"cl'aim to the time credit resolutlon`
system of the Te"Xas Departm'ent of Criminal Justice? _(Th`_is requirement applies to
any final felony convictibn, mcludmg state jail felonies)

l:l yes El `n‘o»

lf you answered yes',`-,answer.~ the.;fo_ll`()\ying questions':

<A) W,h\a'ri-.date did you presem'_che claim-2

 

(B)~ Did yo"u.'l?e,ceivefa" decision and, if yes; what was the dateof'théfdecision?“

.'Iff'you answered no, please.expla_in why'y¢`)`\_i'have,not submitted your claim:--,

R`.<fv._ 01':!`1;4/`1'4

 

"(1_.'1§)

 

 

 

 

 

Begmnmg on page 6, state concrsely every legal ground for your cla1m that you are
being unlawfully restrained and then briefly summarize the facts supporting each
ground You must present each ground on the form application and a brief
summary of the facts If your grounds and brief summary ofthefacts have not been
presented on theforrn appltcatlon, the Court mill not constderyour grounds

If you have more than four grounds, use pages 14 and 15 of the form, which you
may copy as many times as needed to give you a separate page for each ground with
each ground numbered m sequence T.he recitation of the facts supporting each
ground must be no longer than the two pages provided for the ground m the form

You may include with the form a memorandum of law if you want to' present legal
authorities, b'_`u`t the Court will not conslder grounds for relief set out m a
memorandum of law that were not r`ai`s"ed on the form. The citations and arguments
must he m a memorandum that complies with 'I`exas Rulej of Appellate Procedure 73
and does not exceed 15, 000 words if computer-generated or 50 pages if not If you
are challenging the validity of your conv1ction, please include `a summary of the facts
pertaining to your offense and trial m your memorandum_.

Rc\.z Ol /`414:/§.1'4

 

GRGIII‘Jl`)&()l`fl?:.v APPLICANT IS INNOCENT AND HIS CONVICTION IS THE RESULT OF
PROSECUTORIAL MISCQNDUCT: VIOLAT:NG,THE 5TH AMENDMENT AND 14TH AMENDMENT

 

OF THE UNITED STATES CONSTITUTION. §

FACT.S.; S~UPPORTING ‘G~ROUNI) ONEZ»; _
(A) ADDITIONALLY/ APPLICANT CONTENDS, THAT HE HAS PRESENTED CREDIBLE

 

SCIENTIFIC EVIDENCE, THAT "CONTRADICTS THE SCIENTIFIC EVIDENCE RELIED ON

 

BY THE 4STATE AT HIS TRIAL". THUS, INVOKING ARTICLE _11.073(3)(2)\of THE

 

TEXAS CODE OF CRIMINAL PROCEDURE.

 

 

V(C)\ADDITIONALLY! APPLICANT QONTENDS, THE STATE TAINTED WITNESS YVONNE

GONZALES' IN-COURT-IDENTIFICATION. SPECIFICALLY, DETECTIVES EXPOSING

 

GONZALES TO PREJUDICIALLY SUGGESTIVE POST EVENT INFORMATION: DETECTIVES

 

 

T§LLING GON;ALES THAT APPLICANTAWAS A GANG MEMBER. [1]

IN 2014/ GONZALES REVEALED BY WAY OF AFFIDAVIT/ THAT DETECTIVES TOLD HER/

 

THAT "ALL GANG MEMBER WERE CRIMINALS/ APPLICANT WAS A KNOWN GANG MEMBER T

 

AND THAT THEY WANTED ALL MEMBERS OF THIS GANG LOCKED UP."

THIS IS SIGNIFICANT, BECAUSE IN HER STATEMENT/ GIVEN TWO DAYS AFTER THE

 

CRIME. GONZALES IDENTIFIED THREE OF THE PERPETRATORS/ AS TCB GANG MEMBERS.

 

`RC`V. 01'/1:4/1,4.

 

Now, AccoRDING,To GONZALES' TESTIMONY, SHE DID_NOTHKNOW THE APPLICANT.

DETECTIVES TELLING GONZALES THAT APPLICANT WAS A KNOWN GANG MEMBER/ WAS

 

SEVERELY PREJUDICIAL. ACCORDING TO DR. JAMES ALDRIDGE AND ELIZABETH F.

LOFTUS, "SUGGESTIVE POST EVENTI;NEORMATION CAN INFLUENCE A WITNESS' MHKRT§

EVEN SEEMINGLY TRIVIAL INFORMATION AFTER AN EVENT COULD CAUSE LARGE

 

DISTORTIONS IN THE MEMORY. [2] & [3]

 

APPLICANT CONTENDS, DETECTIVES TELLING GONZALES THAT HE WAS A KNOWN GANG

 

MEMBER; WAS PREJUDICIALLY SUGGESTIVE POST EVENT INFORMATION. ESPECIALLY/

PLANTING THE SEED, THAT APPLICANT WAS A TCB MEMBER. THAT IN ITSELF/ WAS

 

SEVERELY PREJUDICIAL, GIVEN THAT GONZALES HAD IDENTIFIED THREE OF THE

PERPETRATORS AS MEMBERS OF TCB.

THE CLAIMS ASSERTED UNDER GROUND NUMBER ONE, ARE SUBMITTED AND CORROBORATED

 

WITH THE NEWLY DISCOVERED AND NEWLY OBTAINED SCIENTIFIC RELATED EVIDENCE/

 

CITED, THEREIN. (FCO]I\UIE: ']HE ASSERI‘ICI\B MAI:E HERE`IN, ARE SJPPCRIEI) BY EXHIBI'IS SLJBV[[T]ED

mmAPPLIcmm No. 49,474-05. [1] see; Exhibit A.16, [2] Sée; E§<hibit E',` '
l[3] See; Exhibit L. ALLFU@C)wmmmNIHEpQH@CHX,THEHLN.) ALL cLAIMs wITHIN
APPLICATION NO. 49,474-05, ARE REASSERTED HEREIN. ` ' `

R`ev,. 01`/§1`4/¢1'4`

 

GRO_UN_I`)?TWO=~: _
\APPLICAN,T ,REASSERTS HIS CLAIMS AS$ERTED\ WHHI.N OR,IGINAL`APPL;CATION, NO- ,, ,,

 

49 , 474-05 .

 

-FACTS§>SUPPORTING.-GR{?)UND.“TWQ=i

 

 

APPLICANT'S CLAIMS ASSERTED WITHIN THE ORIGINAL APPLICATION/ ARE BASED

ON THE NEWLY DISCOVERED AND NEWLY OBTAINED EVIDENCE PRESENTED, THEREIN.

 

 

 

 

 

 

 

 

 

 

Ré.v.-. 0,1./ 114/154

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

R`e_v. 01 `/1'4/14,v

.GR<)UND'THREES.

APPLlCANT REASSERTS HIS CLAIMS ASSERTED W;THIN ORIGINAL APPEICATION NO.

49/474-05

'FACT.,SI;SUPBORTING GROUND THREE

HEREIN/ APPLICANT WOULD ADD THE AMENDMENTS SUBMITTED WITHIN THIS PLEADING.

 

 

 

 

 

 

 

 

 

 

 

=l,`Of

Re_v-. 01/'14/`.14.-

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

111

Re,`v.» OKI-/fl 4/:1'4

-GRo.UN"o EQUR~;§
'APPLLCANT REAS$E§TS HIS CLAIMS AS$ERTED_wITH;N,QRIGINALHAPPLICAjlpm NO,

 

49 / 474-05

 

,FACTSzsUPPORTING:GROUNI) FOU;R,:: .
HEREIN, APPL,ICANT WOULD ADD THE AMENDMENTS SUBMITTED WITHIN: THIS PLEADING.

 

 

 

 

 

 

 

 

 

 

 

'12_\

Rev. 01/..1;,4/14y

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

.1?3

Rev.~Ol)./'l 4./1*4

GROUNI) FIVE
APPLICANT IS INNOCENT AND THIS CONVICTION IS THE RESULT OF CONSTITUTIONAL_

 

WvIOLATioNS: APPLicANT INVQKES A cLAIM UNDER THE PROVISIONS IN ARTICLE 11.073
TEXAS coDE OF cRIMINAL PROCEDURE

 

FACTS#::$UPPORTINGGROUND=
THE ESSENCE OF THE FOREGOING CLAIMS, ARE

 

SUBMITTED UNDER ARTICLE 11.073 (A) THE STATE ELICITED, PRESENTED AND RELIED
ON THE SCIENTIFIC TESTIMONY OF DR. A.J. ALAMIA/ SPECIFICALLY, THAT "THE HUMAN

MEMORY FUNCTIONS LIKE A CAMERA IN TRAUMATIC EVENTS{ l"I‘AK]ING SNAPSHOTS`THATH
STAY INGRAINED IN THE MEMORY'." PURSUANT TO ARTICLE 11.073/ APPLICANT CONTENDS

 

 

THE FOLLOWING SCIENTIFIC EVIDENCE, "CONTRADICTS THE SCIENTIFIC EVIDENCE THE
STATE RELIED ON AT HIS TRIAL".

 

FIRST/ ACCORDING TO THE INNOCENCE PROJECT/ "THE BIGGEST LIE OF THE HUMAN

 

MEMORY IS THAT IT FEELS TRUE. ALTHOUGH OUR RECOLLECTION SEEM LIKE…LITERAL
SNAPSHOTS OF THE PAST/ THEY' RE ACTUALLY DEEPLY FLAWED RECONSTRUCTIONS, A SET
OF STORIES CONSTANTLY UNDERGOING REWRITES." [l] SeCOnd, ALSO ACCORDING TO THE
INNOCENCE PROJECT, IN 75 PERCENT OF DNA EXONERATION CASES,.THE PRINCIPLE CAUSE

 

 

FOR THE ERRONEOUS GUILTY VERDICT, WAS"MISTAKEN EYEWITNESS IDENTIFICATIONS'.
ALMOST ALL THOSE'CASES, INVOLVED A TRAUMATIC CRIME (EVENT). {2} Third, ACCORDING

 

TO NEUROSCIENCE PROFESSOR DR. JULIAN P.-KEENAN/ "IT IS'NOW WIDELY ACCEPTED
THAT OUR MEMORIES/ THOUGHTS, EXPEIRENCES AND FACTS ARE NOT SNAPSHOTS OF THE

 

PAST IN WHICH EVERY DETAIL IS PERSERVED". [3] FOUrth/ ACCORDING TO PIONEER
PSYCOLOGISTS IN THIS PARTICULAR AREA OF SCIENCE: DR. DANIEL L. SCHACTER AND

 

ELIZABETH F. LOFTUS. THE HUMAN MEMORY DOES NOT FUNCTION LIKE.A VIDEO RECO§DER
AND/OR CAMERA. [4] Fifth, PSYCHOLOGY PROFESSOR DR. JAMES ALDRIDGE/ HAS TAUGHT

 

ADVANCE COURSES ON THE HUMAN MEMORY FOR THE LAST THIRTY YEARS. ACCORDING TO
DR. ALDRIDGE, "THE HUMAN MEMORY DOES NOT FUNCTION LIKE A CAMERA IN TRAUMATIC

 

EVENTS":“ADDITIONALLY, DR. ALDRIDGE REVIEWED THE SCIENTIFIC TESTIMONY GIVEN
AT APPLICANT'S TRIAL BY DR. A.J. ALAMIA, coNcLUDING, THE SCIENTIFIC TESTIMONY

 

WAS MISLEADING AND INCORRECT. [5] Sixth, THE NEW JERSEY SUPREME cOURT, IN
1€4

Re\'::. 01/'1"4/1»4

 

vSTATE V. HENDERSON/ 208 N. J. 2081 REVIEWED ALOT OF RESEACH ON THIS SUBJECT
AND THE TESTIMONIES OF NUMEROUS EXPERTS IN THESE RELATED FEILDS OF SCIENCE.
CONCLUDING, THAT THE HUMAN MEMORY DOES NOT WORK LIKE A RECORDER/CAMERA. [6]

BASED ON THE SCIENTIFIC RELATED EVIDENCE PRESENTED HEREIN, APPLICANT C<NIENDS,
THAT HE, HAS _,MET _T_Hg: PROVISIONS_ _sET FORTH BY ARTICLE 11.073(a) (2), respectedlly.

(B) THE STATE TAINTED THEIR CASE AND THE TRIAL/ BY ELICITING DR. A.J. ALNWUVS

 

SCIENTIFIC TESTIMONY, THEN USING THAT SCIENTIFIC TESTIMONY TO BOLSTER THE
TESTIMONIES OF THE $TATE'S KEY WITNESSES DURING`THEMSTATE'S CLOSING ARIM@US.

THE STATE ELICITED AND PRESENTED TO THE JURY, DR. A.J. ALAMIA'S SCIENTIFIC

 

WHiCH CONVEYED TO THE JURY/ THAT IN TRAUMATIC EVENTS THE HUMAN MEMORY WORKS
LIKE A CAMERA: TAKING SNAPSHOTS. [7] IN THEIR CLOSING ARGUMENTS, TO BOLSTER

 

AND SUBSTANTIATE THE TESTIMONIES/IDENTIFICATIONS GIVEN BY THEIR KEY WITNESSES/
THE STA?E EMPHASIZED,AND HIGHLIGHTEDMDR:HALAMIAFS SCEINTFIC TESTIMONY. [8].

 

 

(FOOTNOTE: The assertions made herein, are Supported by exhibitee submitted

with the application for writ ef habeas corpns, filed June 15, 2015, and*

 

found within the Appendix, therein. [l] See; Exhibit A, [2] See; Exhibit M,

 

[3] See; Exhibit F, [4] See; Exhibit B, [5] See; Exhibit E, [6] See;EAnknt

 

A.l, [7] See; Exhibit D, [8] See; Exhibit G)

 

15

Rev-. (:)'1"'/1"4"/ 141

 

WHEREFORE",, APPLIC'AN '1‘ PRAYS; THAT THE COURT GRANT]APPLchNT
l RELI.EFT<;)_ wliicli'»ili~: ‘MAY 'izE EN'iji€l§Lia;i)`.iN' frittsi_izi_tocijzni)mc.,

vit;Ri,FchfrioN

This application must be verified or i_t_ will be dismissed for non-compliance For_
verification pulpo's'e`s an applicant is a person filing the application on his or her own behalf A
petitioner is a personi filing the application on behalf of an applicant for example an epplicaiit? sf-
attorney A-n inmate is a person who is in custody

The inmate applicant must sign either the “Oath Befo`re a Not`ary Publi`c`” before a
notary public or the “llilnate’ s `Declaratioii” without a nctary public l_f the inmate is represented
by a licensed attorney, the attorney may sign the "»‘Oath Before a Notary Publl'_c” as petitioner and
then complete ‘Petitioner s l`ni`ormation ” A non-inmate applicant must sign the “Oath Bcfore a
Notary Public” before a notary public unless he is represented by a licensed attorney iri which
case the attorney may sign the verification as petitioner

A non-inmate non-attorney petitioner must sign the “Qath Be`fore: a_ Notary P'ublic?’
before a notary public and must also complete "“Petitioner’ s lnformz_itioii ” Ai_i inmate petitioner
must sign either the “Qath Bei_`o_r_e a Notary P_ubli_c” before `a notary public er the “Iiimat`e-’ s
Decla'r'atioi`i’_’ without a notary public and rniist also complete the appropriate “Petitloner s"
'Ini`ormation

'oATH' BEFORE» A.,.NOTARY PUBLIC'

smi:i=;~ or TEX»AS-
CQUi\i-"rr? o`i=; ':TQQ g g
M/)/`A WQ/€/my_ / ,being duly sworn, under oath says “I am

 

the applicant / petitioner `(circle one) in this action and know the contents of the above
‘ application for 'a writ of habeas corpus an'_d, according to my belief the facts stated iii the
application are true ”

   

Signature' of ' pp_lijc‘ai_il; '/l_’etitiol'ie'r'? (c'ircle.on'e)

sUBscRii'on AND_. swoRN"'r_o BEFORE M»E rilis,;g&¢ DAY'GF;;§_M, 20 ¢ls/._'

 

tsignaiure¢ri:\lotary remit

16

Rev. y0 l 1141/ill

 

PETI’TI,(S)NER.’s¢iNFORi\/IA'_I?'!QN
l?etitioner?s:priri`ted\nai:ne;z

State ear `niilmber,.ii`f applicable

 

Address;

 

 

 

Telephone:

little

 

INMATE’S DECUARATION

;_l, M/%M 52 , ,amtireapplicant/petitioner(ci`rele ene) and
beingnrcsettliyiiiicarc;erareril 111 _/Z¢ ée/£m/\ 541 /% _,__deciare‘ under penaiiyzor

perjury?that§ -`according to my belie£ the ‘factsf..s_ta'tcdlin the above applicati©ll are true andj'corrcctj.,

Signed on:‘/(éuemée/ 712 _. l ,2Q /{7

%%W%/MMQL

Signature ’ » lié"' fPei:itioiie;r(.circlc orie)l

 

171

'Rcvl. Ol/l"¢l/¥l~.¢l

 

:PETITION'ER’S I,NFO,RMA.'ITION.

Pef,irioner"’;sip.rinted names M7 74/1 /Z"ZW€/?D 7/\ -
Addres's:; 7?§?/;,/6>%@/£"9/~ @/_//_1/7! _
/¢w/ /W v J§Ozz_,_ .

,AM€ z ':@/ %

'I`el`eph`,one-:` .

'Il:ax.: .. ,

signed an /</)¢/Me/ £.,2 ,__20 /5‘/.

WMVQ(

:,»Sf'.ignat:l;r¢. ofil??f:r`ji'ti'ozléf»

185

'Rev,...\oi;_/14/JI,4\»

 

