•/+

HARK ANTHONY YOUNG

VS.

Till STATS OP TEXAS RECEIVEDIN TheCourtofApp^fJSI3--N0, SixthDistrict AU6 172015 Texarkana,Texas * 

### DebraAutrey,ClerK
*

* 

## COURTOFCRPWALAPPEALS 

# AUG272015

3lAC0S»3,w!«« IN THE SIXTH

COURT OF CHXMI3AL APPEALS


### iiUHT 60UHTY, TEXAS 

### SSQU23TFORCOURTAPPOINTED G0UH8SL FILEDIN 

## PUH8UASTTOAHTICLS 1,031, TEXASCOD1 OFdH3^4IF*i!ttSttl^PPEALS AUG272015 TO THE HONORABLE JUDGE 0? SAID COUBTi 

### AbelAcosta,Clerk COMES NOW, the Petitioner, Mark Anthony Young, TDO.T#l929961, and requests the Court appoint counsel to assist him in filing potitfeon for discretionary review and habeas corpus in the above-styled cause pursuant to Texas Code of CriBiinal Proce dure, article 1*051. Article 1.051(d) atatas as follows»,,An eligible indigent defen dant is entitled to have the trial court appoint an attorney to represent bia in 

### the following appellate and postconviction habeas corpus natters: (l) an appeal to a court of appealsj (2) an appeal to the Court of Criminal Appeals if the appeal is nado directly from the trial court or if a petition for discretionary review has been granted* (3). a habeas corpus proceeding if the court concludes that the inte 

### rests of justice require representation* (4-) any otherappellate proceeding if the court concludes that the interest of justice require representation. Aa the Defendant, in the above-styled ciuse postconviction proceedings, he was constrained to respond to an Anders brief, whereas, he has no physical access to research and review his case in compliance with the requirements of ANDEE0 vs. CALIFORNIA, 336 U.S. S.Ct. 1395, 18 L.2d.2d '+93 (1966) and GAIHOU9 vs. STATE. *06 S.W,2d 137, 138(Tex,Crim.App. I969). These ease laws are not available to the Petl

### tione?.'/Defeivi?.'.rb. Also not available to the Petitionsr/Defendant is tne Texas Con stitution, which is a crucial material to his stats conviction, for the Texas Con 

### stitution provides benefits for the Petitioner/Defendant that the United States Constitution doers not (which he has physical access to). The above forgoing case laws and the Texas Constitution has been excluded from the Michael Unit Law Library as 

### communicated and expressed to hira by the SeniorWarden, Eddie Baker* and Law Library 

### Supervisor, Ms. Stotts, they said these will not beraads available to Inmates nor-+

matterwhat litigation the prisoner is in...including post-conviction criminal 

### litigations, Without anyphysical access to these legalmaterials, the Petitioner/ Defendant rights to access to courts has been detrimentally abridged. Under the 

### BoardPolicy NumberBP-03.81 Rules Governing Offender Access to Courts, Counsel, andPublic Officials states in part that, "...Offenders nay present any issue, including challenges to the legality of their confinement...." This Polioywas systeraatically passed at the time the above foregoing case laws and the Texas 

### Constitutionwas available (April 20, 2012). Since September 2013, these wore excluded procedurallyand systematically viathe Michael Unit k& Librarywhich 

### conflicts with Texas Government Code sections ^92.013(a), ^5.025, 499.102(a)$12) and LSWI3 vs. CASEr. 513 U.S. 3^3, 35^355. 116S.Ct. 217*1-, 2181-2182, and the VISiHIiA CONyBfiTIOK03 COIBULAR HALATIONS AND OPTIONAL PBaTOOOLS. article 36. and 

### BQIMB vs. StUTtl. 430U.S. 817, 97S.Ct. 1^91, 5Z L.Ed.24?Z (1977). Petitioner/ Defendant's Declaration in Support of flight to Representation of Counsel is attached and incorporated hereto as Sxibit 1. Respectfully submitted,

EC« File

Page 2 

# teJLuMjJk Marie Anthony/Young, Pro se I92996I, Michael Unit 266*fr F.K. 205^ Tennessee Colony, TX 75886 

### (903)-928-23il//AX-926-2197