COURT OF CRIMINAL APPEALS OF TEXAS P.O.Box 12308 CAPITOL STATION AUSTIN,TEXAS 78711 Julio Torres Palomo T.D.C.J.#1923341 McConnell Unit 3001 S. Emily dr. Beeville, Texas 78102

December 28 

### RPCEIVEDIN 

# ''COURTOF:CRIMINALAPPEALS DEC302015
AbelAcosta,Clerk

Subject: Please stamp & date this Petition. Greetings: May God's blessings be with you &7yours this holiday season... Please stamp & date this petition "Motion for Reconsideration of Appellant's Petition for Discretionary review,with opinion. In it's proper court.

thank you, Respectfully 

## X 

# T^^tP Ct*Z-3fJ&COURT OF CRIMINAL APPEALS OF TEXAS;:' 

### EXPARTE I TR.CT.No.28777 

# JULIOTORRESPALOMO | C0A.NO.06-14-00076-CR T.D.C.J. #1923341 f PD-0425-15 §
Petition's Motion for Reconsideration of Appellantant's Pro-Se Petition for 

### Discretionary Review,With Opinion

TO THE HONORABLE JUGDE OF SAID COURT: Now comes,ExParte Julio Torres Palomo,T.D.C.J. #1923341 currently in confinement at the William G. McConnell Unit 3001 S. Emily dr. Beeville, Texas 78102. In request of Petitioner's Motion for Reconsideration of appellant's Pro-Se 

### Petition forDiscretionary review,with opinion. Petitioner shall show the: following,as this is firmly grounded in the statues and not for reasons to delay justice.
I. On December 16,2015, Julio T.Palomo,T.D.C.J.#1923341,was sent a decision from 

### this Honorable Court stating "Appellant's Pro-Se Petition forDiscretionary review had been refused". It arrived on December 21,2015.
II. According to rules of Appellant Procedure rule 47.1, "The Court of Appeals 'MUST' 

### handdown awritten opinionrithat is asbrief aspracticable but'Which addresses the ev§ry;:;issue-and necessary to finalize the disposition of the appeal"'. Effective September 1,2003. 

### in. REHEARING:Rule 79.1,Texas Rules of Appeellant Procedure. 

### Parties in a Appellant settingmay object,through Motion for rehearing to the Appellant Court's due to failure to address systemic requirements on the original 

### submission. See,Hughesvv. State,(CR.APP.1992),878 S.W. 2d 142.
IV. Remand in the interest of Justice,rule 78.2: When reversing the Court of Appeals, Judgment. TheCCourt of Criminal Appeals,may 

### in theinterest:-of justice remand thecase to thetrial court even if a rendition of the justice is otherwiseappropriate. Effective September 1, 1997.

V. 

### Hughes v. State,878 S.W.2d: 142(Tex.Cr.App.1992). Where an Appellant Court failed to address issues of whether error has been c;s 

### preserved or forfeited by the parties.(due to no error of defendant) theparties may call,to the courts attention for such failure. (I.).In Motion for rehearing. VI. This Motion gives Appellant Court.opportunity to examine an issue possibly over 

### looked, thus promoting efficiency in the legal system. A trial Judge has certain independent duties to perform at a trial,when he fails to perform,any of these duties the parties may object to,through a Motion for Rehearing. VII. 

### The after the fact is not unfair to one party or another... "unless this Court 

### decides,to dismiss this pro-se petitioner 'without awritten order'". Which simply gives this Appellant"no opportunity"to redress the court,then this becomes an issue of a violation of the Fourteenth Amendment of the United States Constitution. 

### Awritten order(brief)is to maintain the essential integrity of the legal system by enforcing all, Appellant courts to observe the systemic requirements. In and for the interest of justice and fair play. It is Petitioner's request that 

### thisHonorable Courtconduct a Rehearing onAppellant's issues and Remand this case back to the Trial Court for a-new"Trial.

PRAYER Wherefore,all premises maybe reconsidered,may this Honorable court,by the almighty grace of God... Grant this Appellant all the issues requested set-forth in his petition,that he maybe remanded back to Trial Court for a new Trial. So helpme God...
Inmate Declaration •.• I,Juilo Torres Palomo,T.D.C.J.#1923341,hereby declare that I am presently at the William G. McConnell Unit 3001 S, Emily dr. Beeville, Texas 78102. I hereby declare under the laws and penalty's of prejury of this State that all the foregoing fac$s and statements are true and correct to the best of my know ledge,so help me God.

Executed on this 28 day of December 2015.

(2). Respectfully Submitted, 

### ,-^Juilo Torres Palomo"

T.D.J.#1923341 McConnell Unit 3001 S. Emily dr. Beeville, Texas 78102