1\&E..L Ac...osT A. ~le.«..K 

S.ld:JI?.E.ME ~ouR'\: S(d.G_, 

2.o l \Al t 41-h s;r. fZ M ,_ lf>1a 

At~...::.:nrJ 1 T~~s /CO/ 11-2.~os RECE\\fEO \N 

COUR1' Of CR\M\NAl AtlPEALS 

MAR, 2 5 ~~15 1l> (;S 

· . A~ Acosta, Clerk 

.I. A..(Y) ·me: .Pe."TlTt\l ,J~ ti\J TMfs ~NfRove.r<.s'/. w UERE TH~ Dt-sfR1c::.:r 

C..lER.K. fZhol'id~ "-v..G,h€'1 REf-V\5.£ To f'RocES.$, rue. rf'Js:fRUIYlEr-llS ~ 

\NA:s. ~RwARcl \o HE.~ aF=,e1 c.E. LlfE" TE.. 'kA.cs C.cat-lS{tT u Tl a('! AR.T1 ~te: c/; 

~E<:..\ ~ Aw-GJ AR'\\c.\E$. l\,os j J·l.o8 J ~<t~ol t\,<.~ ~'tl\.'\ES THA-r TltE · 

\IJR.\t o~ IJ~tt~S C.o-Rf"tAS l·S (}; li\ARAN\"EE.al, fE.Tt\,bNtR ts NQ-t c~~L,tc; 

bh5:.. ~.\S""HJte.T\o~ Arid 'Tt\E. dt-s..lRtc..T ~I eRic. 1 s EN. fibR..(_t NO.. A. RulE tN 

Vloi~o • .J o.te n\E T€~~~, c.al'l~nru'flaN b'l Telf,~~ Tife ~e:flft.orJe-r<. 

He. M~r use. 1lf~ LLor FoRr<l bEFORe f+e CA-r-.1 FRtsc'Ei.s H-ts. wR.,~, 

: M~. ~~~TA, "fou 1-t,._v(:: THE Alll'fffoR\T"/ ra t'Roc.~ss Tlft!. ~Y.~rlel<!s 

WR([ 1 N. Tit£ TRtA( Co(ART • .L Ar<\ RE.<3\AE.s1JI'l~ ·ru~T Tf:fE dt~TR\c.f 

C.(~k. f't<cc~ ~~ LEGAL .IN~\Rur<1l!NTS A ITAdfa:J, 

~·!_( ------~ .l<,e:V"lN f'll~[~'tl\11 t!:'FF- 172..1l1Y 

. RECEIVED IN .. • 

COURT OF CRIMINAL APPEALS 

~ ~PR 17 2015 Gf.;~ ., ' • ·r • 

· Apel Acosta, Clerk 
February 24,2015 

Rhonda Hughey 

District Clerk 

County Courthouse 

100 w. Mulberry · 

Kaufman, Texas 75142 

RE: FILING WRIT OF HABEAS CORPUS 

Dear Ms.Hughey, 

Enclose please find the following instructments to be filed IN YOUR 

OFFICE for the district court's review of ihe merits. 

1. Application for writ of habeas corpus 

2. Request for legal representation 

3. Notice of deposition by written questions 

4.Daeposition by written questions 

' 

5. Petition to take deposition to investigate potential claim 

6. Request for a hearing ,•'. 

These are the original document's and a copy has be ~forward to 

Mr.Dennis Patman Jones for his review. 

Ms.Hughey, I want to thank you in advance for your assistance-in this 

urgent matter. 

c. c. filed 

/S/ 1( .__ yJ")T 

Kevin Menniefee 

-·--· 
~,. 

. ·' 

~~uq~ ~0. 28736-86 

STATE OF TEXAS § IN THE DISTRICT COURT 

vs. § 86th JUDICIAL DISTRICT 

KEVIN MENNIEFFE § KAUFMAN COUNTY, TEXAS 

APPLICANT'S APPLICATION FOR A WRIT OF HABEAS CORPUS 

PURSUANT TO THE TEXAS CODE OF CRIMINAL PROCEDURE -. 

ARTICLE'S 11.01, 11.02, 11.04, 11.05, 11.08, 11.23, 11.42, and 11.43 

... TO THE HONORABLE JUobE OF SAID COURT: 

Now Comes, Kevin Menniefe, TDCJ-ID No.· #1727174, appearing pro...:se, thereafter referred 

to has the applicant, and he petitions said court pursuant to article's 11.01, 11.02, 

11~04, 11.05, 11.08, 11.23, 11.42, and 11.43 of the Texas Code of Criminal ~rocedure. Also, 

pursuant to Article 1, section 12, of the Texas Constitution, and Article 5, section 8, 

of the Texas Constitution, that he presents his application for Writ of Habeas Corpus, 

to determine whether the State Court lacked jurisdiction of the subject matter or oy~r: 

the applicant, and is he illegally confined or restraint in his liberty within this courts 

jurisdiction. Applicant request that this court conduct an 'evidentiary hearing and obtain 

wr~tten deposition's from his trial attorney and the accomplice witness pursuant to article 

' . . ' 

39.02 and 39.06 of the Texa:s Code of Criminal Procedure. 

I. 

JURISDICTION 

Pursuant to article's 11.01, 11.05, 11.08, 11.23, 11.23, 11.42, and 11.43 of the Texas 

Code of Criminal Procedure, this Court has jurisdiction to grant the relief requested 

herein. see EX PAFTE POWELL, 558 SW.2d. 480,481 (Tex.Crim.App. ~977): and EX PARTE WILLIAMS 

786 SW.2d. 781,782 (Tex.App.-Houston [ 1st Dist I 1990, pet~ ~ef'd ). 

I . 
SPECIAL STATEMENT TO THE COURT 

Applicant is an indigent prisoner, layman of the law, acting without counsel, and as 

such requests that this court not to impose upon him the same high standard of the legal 

art which may be placed, in a pleading to prepare and filed by a learned member of the 

State Bar. Applicant further request that this court will consider this pro-se applican 

tion in a manner that will do substantial justice, with a measure of tolerance, pursuant 

the opinion in HAYNES VS. KERNER, 92 S.Ct. 594 (1972) •. 

II. 

STATEMENT OF THE CASE 

1t . . J! 

THE UNDERLYING PROCEEDINGS. Applicant, Kevin Menniefee, is being held illegally in the 

Texas Department of Criminal Justice -ID, from a judgment interred in on Novemeber 17, 

2010, in the 86th District ·court, Kaufman County, Texas in cause no. 28736-86. 

THE RESPONDENT'S. The respondent's are the S0nTE OF TEXAS and app~lcant's trial attorney 

Dennis Pl':itman Jones, of Kaufman County, Texas. 

RESPONDENT"S ACTION. Respondent illegally confined and restrainted applicant on April 30 

2010, after the Honorable Howard V. Tygrett, pr;-esiding judge of the 86th Distrcit Court, 

of Kaufman County, .Texas, rendered judgment in two separate trial's under one indictment 

in cause no. 28736-86. 

APPLICANT'S RESTRAINED. Applicant is illegally confined and restrainted in the Texas 

Department of Criminal Justice-ID by the respondent's in violation of.the United States 

Constitution; Texas Constitution Article 1 § 10, to be· indicted by a (irand Jury and the 

'Statutory provision's setforth in the Texas Code of Criminal Procedure Ann. Atticles 

§§ 1.04; 2.04; 2.05; 15.04; 11.23; and 21.22. 

2. 
III. 

STATEMENT OF FACTS 

Appl~cant's original indictment alleged that he committed aggravated robbery,, a frist 

degree felony, pursuant to the Texas Penal Code §§ 29.02 (a). On September lOG,20lO::·. the 

State_,q_:l:. Texas amended the indictment to add§§ 29.03 (a)(3)~~), which are two separate 

and distinct offense's, amended by interpolate of the indictment alleg~ng Hindering 

Apprehension or Prosecution as Count TWO • There was no "VICTIM" asserting a criminal 

complaint or accusing the applicant of a crime against the laws of the State of Texas. 

The information based upon the complaint did not allege that the applicant engaged in 

an affirmative act that promoted the commission of the offense that the applicant is 

accused of. 

Under the Due Process Clause of the Fourteenth Amendment, an accused in state court has 

the right to the "presumption of innocence", i.e., the right to be free from criminal 

conviction unless the State can prove his guilt beyond a reasonable doubt by probative 

evidence adduced at trial. When a jury is told of the presumtion , it is told, in effect, 

to judge an accused's guilt or innocence solely on the basis of the evidence adduced at 

trial and not on the basis of suspicions that may arise from the fact of his arrest, 

indictment, or custody. 

The burden of proof in all criminal cases rests upon the State through9ut the trial and ., 

never shifts to the defendant •. "All persons are presumed to be innocent and rio person 

may be convicted of an offense unless each element of the offense is proved beyond a ~. . 

reasonable doubt. The fact that he has been.arrested, confined, or indicted for, or other- . '• . . .. 

wise charged with the offense gives riseto no inference of guilt at his trial. The law 

does not reqtiire a defendant to prove his innocence or produce any evidence at all. 

'rhe pres·w.1pt ion o:C innocenL:e a.i.one is .su C:dcient l:.o acquit the defendant, ur!le::;.s the 

jw:.·o:t:·s a~e satisfied beycmd a_ n~a:.sonabl€· doubt of ;~he defendant! s guit: after· car:et:u:l and 

.impartial con:=,lder·ation of aU tite 2viuence in the case. 'l'he prosecution has the bur-den 

:;i p~oving tne uefenJant guilty anC it. um:Jt do =30 jy proving each and every element of 

tile offense charged beyond a reasonable dot::bt and if it fails to do so ' the defendant 

must be acquitted. 

3. 
Defense Cuunsel 's sh_ould explaL1 the nec~ssity of full disclosur·e of all [acts known 

to his client foe an effective defense. Counsel, should assU111e .t:E:spons.i.bili:.y for· technical and le9al, str·ategic anu tactical lsoues, such as whai.: witness to ccill, wh~i.:her and 

how i:o conduct cross examination, what jm:or-s to accept or str:ike, what 111otions to !llake, 

anc1 what evidence 1:0 introducE:. But counsel ohould const::lt YTith his clhmt on these 

qt::e.stion 1B where such consultation is feasibl!:!. 

It is £undament.C:tl that a ue.fense counsel must be sc.cupulously candid and truthful in 

t·eptesentat.i.ons of any mat tee before c.t cpurt, this is· not only a basic ethical requir:eliietJt but i.t is e::>s8ntial if the counsel is to be effective in his ro1e of advocate for 

i£ cuunsel !s reputation for: vet:ac.i.ty is suspect, he will lack. the confidence of the cour<: 

when ii: i.3 needead most to .se:r:ve his client.· Applice:un: contends L:hat his ~:>!counsel failed 

his legal duties to :cepcesent his cas~ in a couct of law. 

CLAIM 1 0F DEPOSITION OF DENNIS PATMAN JONES 

Appellant was not fully informed of his legal rights when he was interr 

-ogated by the Forney Police Department. In which he did stta.te that he was 

present at the scene of the crime. There was no evidence sh6~ing thai the 

appellant engaged in an affirmative act of committing the alleged robbery 

or hinding the apprehension of John Mitchell. The complaint written by 

officer Shane Prewitt did not al.lege that the appellant robbed anyone. 

The trial court lack jurisdiction over the subject~matter. Officer Shane 

Prewitt, complaint was based upon an unfounded theory of the States prosecutor, and the appellant's presence at the scene of the crime did not 

include a culpable menti'll state or states of the offense. 

·Appellant request the deposition of written question's of his trial attorn 

-ey Dennis Patman Jones and John Mitchell to show that the trial. court did 

not have jurisdiction over the appellant or over the case at bar. 

4. 
v. 

RELIEF REQUESTED 

In this writ of habeas cor.;.pus, appellant seeks to resolve the dispute· 

of a legal question of law in cause no. 28736-86 (Trial)), which trans1 

pired during his pretrail and jury trial proceedings. Appellant request 

a written deposition from his trial attDrney Dennis Patman Jones to reJolv 

the disputed legal questions of law as the questions are a result of hJs 

professional judg~ent and reasonableness. I 

VI. 

UNSWORN D.EI:: LARATION 

I, Kevin Menniefee, #1727174, am presently incarcerated in the ~~B~ Ellis 

Unit, in Walker County, Texas. I declare under penalty of perjury that the 

facts stated in this document are true and correct. 

EXECUTED ON FEBRUARY 24,2015. 

VII. 

/S/1\~-~ Kevln Sharon~ $1727174 PRO-SE 

CERTIFICATION OF SERVICE 

I,Ke~in Menniefee, #1727174, certify that I sent a copy of his "Application for a writ of habeas corpus purstlant to the Texas Code of Criminal 

Procedure, articl~s 11.01; 11.02; 1~.04; 11.05; 11 .. 08; 11.23; 11.42; and 

11.43, through the U.S. Postal Serv&ce, to 

Rhonda Hughey 

District Clerk 

County Courthouse 

100 W. Mulberry 

Kaufman, Texas 75142 

C. C .. FILED 

5. 

RES~~. SUBM~TTED . 

O.B. 

Kevin 

1697 

Ellis 

FM 

Menniefee, 

980 

Unit ~ 

Huntsville, Texas 77340 
,, 

FebrHn.ry ,.2.015 

Kevin Sharone Menniefee 

TDCJ"-ID NO. 1727174 

O.B. Ellis ur.it 

1697 FM 980 

Huntsville, '!.'exa.s 77340 

'Ihe Honorable Presiding Judge 

The Distcict Court 

County Cou:cthouse 

100 w. Mulbercy 

Kaufman, Texas 75142 

J 

RE; Ke.vin S. J.Vienniefee VS. 'I'he State of '.I'exo.s 

'J:r. ial Cour.'t No .. ,#28736-86 Count 1 

REQuEST E'OR LiliAL REPRE.SENTAIIOl-J 

Your Honor, 

I, Kevin 1-lenniefee, the uud::csi9ned, her;:by ce:ctify under penalty cf perjury tf1at the 

followif19 facts at'e true and cor·rect to the best o:C my abl.lity. 

l. I dill the appellant ln the above - named matt.er.' and desire the assistance of counsel in 

this proceedings. 

2. App2llant repr,es.:nt to the cou:ct. that his request:. for.· de:position by written question(s) 

a.::·e es.sential to the incet·est oi justice in this cd..se, ar1d failure to consicec appclla;rt; s 

l..~equest will re.:;ult in a substantial mlscC:t:t:Tiage of justice~ 

3. Appellant represent to the court th.:J.t it i.s beneficial for the court to appoint an 

private investigator to obtain the facts in support of the deposition. 

4. Appellant represent to the court that the is.suGs raised in his writ of habeas corpus 

will detemtine the trial coucts jurisdiction and the subn}ec:t-matte:c that the :1ppellant 

believes are meritorious. 

5. J.l.ppellanl: repr:esent to the couct th~at w·ithcut the courts rendition of judgmentt appe·~ 

l~ant will suffe:c o. :.:..·emedy a-c law and- access· to the court's. 

6. Appella:nt represent to the c:ou1·t that i1e is witilouc mo11ey or means witil which to employ 

an attorney, .::..nd S;) he is unable financially to retain co .. msel [oc hiii1self. 

'I'het-efcre, Appellant pr·ay that the cou:t:'t p:.:..-ovide counsel in his behalf. 
CAUSE NO. 

KEVIN 3HARONE .l\'iENNIBFEE / IN THE DISTRICT COURT 

\ 

\ 

vs. o6ti1 JUDICIAL DISTHIC'l' 

DENNIS FA'.i'f·1AN .:.iON83 § KAUFMAl\l COUNTY, 'l'EXAS 

KEVIN S. MENNIEFEE;S NOTICE OF DEPOSITION BY WRITTEN QUESTIONrs) 

TO: Dennis Patman Jones 

Attorney at Law 

201 W. tv:ulber:cy 

Kaufmant, Texas 75142 

·: 972 ) 962-8800 

~972) 962-3733 

State B~r No. 10369880 

1. Please take notice that, 

39.03; 39.04; at'.d 39 .04, the 

200.4; Kevin l",enniefee, ;.,ill 

Jones, on at 

undc:.:- Texas Code of Criminal P:cocedur:e, A:t:ticlGs §§ 39.02; 

fcrrnalities arG gov·e:r·ri by th·c 'I'exas F~ule c~ Cilzil Procedure 

take the d:aposi tion by wri tt:an que::rtim:. 's of Dennis f'.=i;::nan 

at the county courthouse, 100 v;. 11ulber-ry, Kauima;,, ~--------- -----~- 'l'cxas 751:42. 

2. 'The dcpositicra -lrlill co:ntir1ue ·from day ·to da), u11til ccnpleted~ 

3. 'l'hc C.epo.si ~ion ~o.·ill be taken by the Distirct Judge, at thG cour:.ty courthouse:, i:1 

Kaufman, Texas. 

CERTIFICA~'E OF SERVICE 

This is to certify.thai: on the file Jate a i:cue and <.:otTect copy of the aoove and 

fo:cagoing document was set·ved on the District cle:ck Rhonda hughey, county cou:cthouse, 

100 w. 11ulbe:ct:y, Kauntan, 'rexas 75142. 

C.C. FiLED 

;sF~~-~ Kev·in s. 1\ienn.:t:efee # . .L727174 

Appeacing P;t:o-Se 

o.s. Ellis Unit 

169'7 FM 980 

Huntsville, 'I'exas 7'7340 
CAUSE NO. 

KEVIN SHARONE MENNIEFEE § IN THE DISTRICT COURT 

vs. § 86th JUDICIAL DISTRICT ../ ~ ' ..J • 

DENNIS PATMAN JONES § KACFi''L\::'l COUNTY, TEXAS 

DEOP 

DEPOS::i.'I'ION BY WRITTEN QUESTION(S) 

1..· Please state you:c full name, occupc.ti0n, and official title. 

ANSWEH: 

2. A1·e you ti1e .::ustoaian of rEcords fo.c the titl~ cause no. Kevin !1enniefee vs Th2 State 

of Texas 28/36-86 1 

ANSwER: 

3. What v:ere the charges against Kevin Mennief~e ? 

ANSWER: 

4. Did you represent Kevin Mermiefee in a jur-y trial on Ncvemb•?.::- l5,20J.D thu:c November 18 

2010i in cause no. 28736-86 ? 

Did :cep:cesent Kevin M·znniefee ... .., .u. both chc.rges ? 

ANSWEf!~ 

6. ~\'Thy did Keuill'n r'iE.:rmiefee have separate trial 1 s onrl:t.hE!S·e two charges ? 

7. At lvhat f.'Oint did the State of Texas amended Kevin Menniefee 1 s inai::::trnent to add 

another: ..::r:iminal charge ? Plec.se give the C:ute. 

l. 
ANSWER~ 

8. Did you file a !LiOtion to "ELEC~" on your cli·<mt t'ienniefee behalf -:· 

AnSWER: 

9. Did you file a motion to quash the lnC:iccment J?u:csuant to al."'"t. 28.05 of the 'l'ex. 

Coae of Cdminal ?rocedure ? ANSWEH~ 

10. Did your client l\1enniefee evei· tell you 'Mr.Jone::.: that the co-defendant Jdm Nitchc;ll, 

"Told him to stop the car, ar,d fm: him to go jack that lady 1 (the victim) 1 and he told 

IvJitd;~ll 'hell' no" ? H. 

ANSW.t;R; 

ll. l\'ir. Jcnes, in your professional opinion, were both criminal charges from the .:>ctme 

episode.· ") Dces the misjoinder occur and constitute· fundamental (:!rror· ? 

ANSvmR: 

12. Mr. Jon.:~s, in you!:" professional opinion should a motion to dismiss: the indictment :·: 

been filed ? 

ANSWER: 

13. Was there a motion in limine filed in your client Menniefee;s behalf ? 

AN"SWER~ 

14 .• JVJr. Jones, m.o you object to your client fvlenniefee' s amended indictment ? 

If so, give a date '? 

ANSWER: 
15. tVJr. Jones, in your professional opinion, were the charges separate and distinct 

offenss:s ? 1 

ANSWEi:Z: 

16. Mr. Jones, in your professionai ·opinion, ·was your client fvlenniefee in formed of 

the nature and cause cf the accusation agains·i: him ? 

ANSWER: 

17. i"lr. Jones, did the comp.La~nt a.L.Lege that your client r1enniefee engaged in an 

affinnative act that: promoted the canmisaion of either- of the two offense's that he 

has been convicted of ': 

ANSWER~ 

18. Mr. Jones, did the grana Jury assest whether there was probable cause to believe 

that your client i•ienniefee committed both these charges ? 

ANSWER: 

19. ivl:c. Jones, did you make any objections to the complaint or the indictment before 

the date the trial coirunenced ? 

20. Mr. J·ones, in your professional opinion, is your .;lient fvJenniefee guilty of the 

charges that he mas been charged with ? 

3 
• ·} t 

IN RE KEVIN SHARONE-MENNIEFEE, 

Petitioner. · · 

CAUSE NO. 

§ 

§ 

§ 

§ 

§ 

IN THE DISTRICT COURT 

OF KAUFMAN COUNTY, TEXAS 

86th JUDICIAL DISTRICT 

NOTICE TO DEPONENT OF HEARING ON 

PETITIONER KEVIN MENNIEFEE'S PETITION TO INVESTIGATE CLAIM 

TO: Dennis Patman Jones, 201 w. l\1ulberry, Kaufman, Texas 75142. 

Petitioner, Kevin Menniefee, has filed the attached petition asking the court for permission to take your deposition on written questions to investigate a potential claim 

by petitioner, and the court will consider the motion on this 

AT this time ---------------------------

RESPECTFULLY SUBMITTED 

CERTIFICATION OF SERVICE 

I, Kevin Menniefee, #1727174, certiff that I sent a copy of his Verified petition to 

take deposition to investigate potential claim, through U.S. Postal service, to the depose 

Dennis Patman Jones, .201 W. Mulberry, Kaurnan, Texas 75142. Phone no. (962) 962-8800 

on February ;2_\..( , 2015. 

C. C. FILED 

/S/ ~K~e~v~i~n~S~h-a_r_o_n_e~M~e~n-n~i-e~~~~~~~ 

O.B. Ellis 

1697 FM 980 

Huntsville, TeXflS 77340 

Appearing Pro-~~-
CAUSE NO. 

KEVIN~'SHARONE MENNIEFEE 1 § IN THE DISTRICT COURT 

vs. § 86th JUDICIAL DISTRICT 

DENNIS PATMAN JONES, § KAUFMAN COUNTY, TEXAS 

PETITIONER KEVIN MENNIEFEE'S VERIFIED 

PETITION TO TAKE DEPOSITION TO INVESTIGATE POTENTIAL CLAIM 

Petitioner, Kevin Menniefee, asks the court for permission to take a deposition on 

writen questions of Dennis Parman Jones, to investigate a potential claim by petitioner 

as allowed by Texas Rule of Civil Procedure 202. 

1. Petitioner, Kevin Menniefee, is a State prisoner confined to the Texas Department of 

Criminal Justice, at the O.B. Ellis Unit, in Walker County, Texas. 

FACTS 

2. Dennis Patman Jones, is the trial attorney that repersented the petitioner in his 

jury trial, in the 86th Judicial District Court, Kaufman County, Texas. 

3. Petitioner, seeks to depose Dennis Jones to investigate a potential claim by petitioner 

arising out of Mr.Jones representation during petitioner's pre-trial proceedings and jury 

trial from Novemeber 1,2010 through November 18,2010. 

4. This petition is filed in the 86th Judicial District Court, Kaufman County, Texas, 

where Dennis Jones practice law as an attorney. s-~e Tex.R.Civ.P. 202.2(b)(2). 

REQUEST TO DEPOSE 

5. Petitioner, asks the court to issue an order authroizing him to depose Dennis Jones, 

who resides at 201 w. Mulberry, Kaufman, Texas 75142, and whose telephone number is 

(972) 962-8800; 1972) 962-3733. State Bar no. 10869880. 

l. 
6. Petitioner expects to elicit the following testimony from Dennis Jones, what was his 

trial strategy when he did not allow the accomplice witness John Michell to testify in 

the petitioner's behalf, and his involvement in robbing the victim? Why, din't Mr.jones 

interview John Mitchell before trial to obtain an affidavit ? And "WHY" didn't Mr.Jones, 

interview any of the State's witnesses and obtaim an affidavit from them ~s· to the witnesses facts as to what they saw ? 

7. Petitioner needs to depose Dennis Jones because he d~d not investigate the facts and 

petitioner's innocence that was clearly presented at his jury trail. 

HEARING 

8. After service of the petition and notice, Rule 202.3(a) requires the court to hold 

a hearing on the petition. 

9. At the hearing, the petitioner will show that the likely benefits of allowing the dep 

-osition to investigate a potential claim outweighs the burden or expense of the procedur 

see Texas Rule of Civil Procedure 202.4(a). 

PRAYER 

10. For these reasons, petitioner asks the court to set this petition for hearing and, 

after the hearing, order··the deposition of Oennis Patman Jones. 

RESPECTFULLY SUBMITTED 

2. 

pro-se 
VERIFICATION 

STATE OF TEXAS § 

COUNTY OF WAL~ER § 

Before me, the undersigned notary, on this day, personally appeared Kevin Menniefee, 

a person whose identity is known to me. After I administered an oath to him, upon his oath, 

he said he read the "Verified petition to take deposition to investigate potential claim" 

AND that the facts stated in it are within his personal knowledge and are true and correct. 

UNSWORN DECLARATION 

,Kevin Sharone Me efee 31727174 

Appearing Pro-Se. 

I, Kevin Menniefee, 1727174, am presently incarcerated in the O.B. Ellis Unit, in 

Walker County, Texas. I declare under penalty of perjury that the facts stinted in this 

document are true and correct. 

EXECUTED ON February 24,2015. 

/S/ ~ ~.(----- . Kevin Menniefee #1~4 pro-se 

CERTIFICATION OF SERVICE 

I, Kevin Menniefee, #1727174, certify that I sent a copy of his Verified petition to 

take deposition to investigate potential claim, through U.S. Postal service, to the depose 

Dennis Patman Jones, 201 W. Mulberry, Kaufman, Texas 75142. Ph~ne no.(962) 962-8800 

on February !t:{ , 2015. 

C.C. FILE 

3. 

/S/ Kef.fs-:::one Mennf5:it;;;; 

0. B. Ellis Unit 

1697 FM 980 

Huntsville, Texas 77340 

Appearing Pro-S~--