•/+

HARK ANTHONY YOUNG

VS.

Till STATS OP TEXAS

RECEIVED IN

TheCourt ofApp^fJSI3--N0, Sixth District

AU6 1 7 2015

Texarkana, Texas *

Debra Autrey, ClerK *

*

COURT OF CRPWAL APPEALS

AUG 272015

3l AC0S»3,w!««

IN THE SIXTH

COURT OF CHXMI3AL APPEALS

iiUHT 60UHTY, TEXAS

SSQU23T FOR COURT APPOINTED G0UH8SL FILED IN

PUH8UAST TO AHTICLS 1,031, TEXAS COD1 OF dH3^4IF*i!ttSttl^PPEALS

AUG 27 2015

TO THE HONORABLE JUDGE 0? SAID COUBTi

Abel Acosta, 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 other appellate 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 Petltione?.'/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 Senior Warden, Eddie Baker* and Law Library

Supervisor, Ms. Stotts, they said these will not be raads available to Inmates no
r-+

matter what litigation the prisoner is in...including post-conviction criminal

litigations, Without any physical access to these legal materials, the Petitioner/

Defendant rights to access to courts has been detrimentally abridged. Under the

Board Policy Number BP-03.81 Rules Governing Offender Access to Courts, Counsel,

and Public Officials states in part that, "...Offenders nay present any issue,

including challenges to the legality of their confinement...." This Polioy was

systeraatically passed at the time the above foregoing case laws and the Texas

Constitution was available (April 20, 2012). Since September 2013, these wore

excluded procedurally and systematically via the Michael Unit k& Library which

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. 116 S.Ct. 217*1-, 2181-2182, and the

VISiHIiA CONyBfiTIOK 03 COIBULAR HALATIONS AND OPTIONAL PBaTOOOLS. article 36. and

BQIMB vs. StUTtl. 430 U.S. 817, 97 S.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