__ Pr PARTICULAR VERDICT, 1S IRRELEVANT = IF He
__INTENSTIONALLY OR KNOWINGLY OFFERS CONFERS, OR

__ AGREES To_CONFER_ON_ ANOTHER» . ANY BENEFIT

AS. CONSIDERATION FOR THE RECIPIENTS DECISION, ———_!

VOTE, RECOMMENDATION ,.OR_OTHER EXERCISE OF

OFFICIAL DISCRETION... 2. NA TUDICIAL OR ADMIN |
__ASTRATIVE PROCEEDING...

_@)._1N- THE COURTS FinDiNGS AWD CONCLUSIONS * (T.STATES

_THAT_THE_APPLICANT..DOLS NOT ASSERT THAT THe STATE
DID NOT_DISCLOSE THE EVIDENCE. THAT. THE ComPLAIWANT
HAD ASSERTED SHE WAS SEXUALLY ABUSED BY ANOTHER —..
—TJHETRIAL RECORD 1S _CLEBR. THAT THE STATE KNEW OF.
THIS BUT FAILED TO BRING To TRE INVESTIGATION. ALL.
THE _2V DENCE TENDING TO. PRODUCE CONVICTION. OR -
__ACQUITTAL - Stt WRIT_ATPG8-9. FURTHER WHE
APPLICANT ATTEMPT ED Th RAISE THIS AT THE PUNISHMENT
He Was INSTRUCTED BY TRIAL _CouseL_NoT To Go
_Tht&e.. THEREFOR’ Born THE STATE As WELL AS
__ TRIAL. COUNSEL WERE AWARE. .

AN. NO_AFFIDAWIT FROM FORMER SODGE MICHAEL SwiPes
NOR APPELLATE CounISéL. IT IS BELIEVED THAT .



LSSUZS REGARDING JUDICIAL MISCONDUCT AND FUROR _-

MISCONDUCT ARE BASED ON THE RECORDS STATING THAT.
_ THE CooRT BOUGHT LUNCH FORTHE TuROkS SO THAT
__THEY COULD CONTINUE DELIBERATIONS.” THE TRIAL
RECORD REFLECTS : VOLS, PG 143 Lines 13718 —
__ “OKAY, FOLKS. IT 1S LUNCHTIME.. THE PIZZA IS NOT
__HERL.._IT_ SHOULD Bt_IN_A SECOND. THERE ARE DRINK.
__ MACHINES. DOWN THE HALL... DON'T TALK ABOUT THE
__CASE.. AND BE BACK HERE READY TO. GO AT 1200 O'CLOCK. _
ALL RISt FOR THE FURY, (THE TuRy LEFT THE CORT
Room), THIS WAS AT APPROXIMATELY }(2 30/1235 A.M _
@ hus, THe ARIAL CouRrS_FinipinGS THAT THE COURT
RouGHT LUNCH FoR THE SURRS So THAT THEY
__COULD CONTINUE DELIBERATIONS 1S A GROSS MIS~
STATEMENT THAT. BORDERS TUDIGAL MISCONDUCT.
BY AE TRIAL _CBURT_1n_ ITS FINDINGS AND CON-
—_CLUSIONS OF LAI, — _
THE SURY DID NOT START _DZLIBERATIONS UNTIL
(WELL ARTER LUNCH, Sez VOL.3 Pr2 PG 1gs
Linels) (8,19 “ pil Rise FoR THe JURY. (TURY LEFT
__ THE COURTROOM), a a
__ REGARIING WHETHER THE COURT [Did] 08 DID NOT.CoN—__-
__BPITION HIS PURCHASE OF LUNCH ON THE TURORS RENDRING

e@ _ _ a
__@ 7 _



THE TRIAL Tune , MICHAEL SNIPES, HAS RESIGNED
__ AND THAT. _PUBLIC. DeFenoge KATHLEEN) WALSH FAILED
__7To_MAKE Hee AFFIDAVIT

WHEREFORE, APPLICANT PRAYS THAT. THIS HONORABLE

_.COURT_OE_CRINOINAL APPEALS ACCEPT AND CONSIDER

__APPLILANT'S RESPonise IN_OPPOSITION / REBUTTAL To.
_ THe TRial_ Covers! FINDINGS - AND CONCLUSIONS OF

LAW. _ ee
RESPECTFULLY, _

e . —GAYLann Loraar eons! “inten

PoLunsky_ uni T-
— 3819. F.M..350_SouTa
LIVINGSTON, TEXAS. “1735 J.

a _ CARTIRICATE. oF Sepuiek. _.
ZL. GAYLAND LAMONT EpwARDS, NO. 1764899 ATIEST_UnDER
__PENALTY_OF PERTURY THAT ALE THINGS CONTAINED Here
PRE PRUL AND CORRECT | _.
Gano Lamon epuannos P4894
e@ : _ _
Swen . _01/ 14 201s a



93, 31S A

. _—IN THE CoukT OF CRiMINAL.__BECEIVED IN -
© APPEALS.OF TEXAS ‘Door i en 7
. JUL 23 2015
EX PARTE _ ___ WR Tala Aone, Clerk
—ARYLAND LAMONT. EDWARDS — WIO=55217=Y (A).

__APPLicanrT’S RESPonSE. tn OFPOSITION | REBUTTAL. To
____TRIAL_CouRTS Finbin@s OF Fact /ConCLUSionS OF LAL

_-INEFFECTAVE. ASSISTANCE OF COUNSEL — TRIAL. a
W). THIS WRITER FOR APPLICANT AGREES THAT THE CiTéD
—CASES_IN THE TRIAL COURTS FINDINGS AWD-CONCLUSIONS —
—1S_RELEVANT_CASE LAW. HOWEVER, THESE CASES ARE
@ io Lorate PREVAILING NORMS OVE TO THE Revision
__ AMENDMENT Fo ARTICLE 1.051 CALSO KNOWN AS THE _
Tas FAIR DEFENSE ACT) T.O.C.P., EFF. SAN. 01,2002

" __ASD_ARTICLE 26.04 T.C.c.P.

(i)(6)_APPLI CANT ASSERTS THAT TRIAL COunstU's FAILURE To |
RE-URGE OR OBTECT_ IN RELATION To THE STATESUINTENT
To_nSTRODUCE.. EVIDENCE. THAT WAS NOT ALLEGED In THE CHARGING
INSTRUMENT PRIOR TOA REQUEST FoR A Li iTING IWSTRUCTION.—_
COUNSEL KNEW THIS EVIDEICE WAS GOING TOBE INTRODUCED

NET FAILED fo RE- URGE THIS O8TECTION. a

—— ©.


(Cc), @_1T Arrears THAT TRIAL Counsec 1S ATTEMPTING To
Twist “THe FACTS b) HIS FAVOR . No ent, NOT THIS

WRITER. NOR APPLICANT. WOULD EVER ABANDON ANY SuCH

FACTS THAT ARE SUPPORTED BY THE TRIAL RECORD OR.

Pw OTHER SUCH. RECORD THAT 1S“ CAPABLE OF. PROVING
_ DEPENDANT. PealDAnT | APPLICANT'S INNOCENCE. _

UI) E)_APPLICANIT WOULD REFER THIS HOWORABLE COURT To
THE TRIAL RECORD: No WITNESSES WERE ASKED AT THE
_PuuISHMEWT PHASE. “IF THEY THOUGHT THER TESTI MOY
WOULD HAVE MADE A DIFFERENCE HAD THEY Beta) PRESEOT
AND CALLED DURING APPLICANT'S GUILT /iNMOCENCE PHASE
OF TRIAL;
Rt? vol3, Pt a! Po. 201 Lines 18-20 VICKL EDWARDS”
PGA Lines 19-31 “'SO HAO T. Caurep YoU eARLigR
__ To TESTIFY, YOU WOULD HAVE HAD Td EXPRESS THAT. ‘saint.
TRUTHFUL AND HowesT OPINION LET HAD. ASKED You.
THAT; ” isw'T. That RIGHT 2
(THe pRoblem Les WIE” DL HAD ASKED 400 THAT.)
Ris VOLS, PH2 PG. Da Lites 1-4 “TRUK EDWARDS ”
PG, 214 Lints [4-20 “So You WOULDN'T Have Breas

BLE To TESTIFY. ABOUT ANY OF THE PACTS OF THE CASE

— RAGHT_ 7 (AGA, BW THE ABOVE QuEsTiON 1s Ime PnPLLEo)_.

oe Se © 7



@ — |
RE! VOLS PE2 PG, AIS Lines 5~'T “TABITHA RONEY.” :
POS. DNo - BHAT. LNs 34-25 “AND So, IFT Had

_OF CALLED YOu To TESTIFY_IN FRonT OF ATURY
ALITTLE 2ARLIER , You CHave] Would Have To =

“(uwes), 1 PG, aI7) BE TRUTHEOL ABouT THAT ANID SAY

_WHAT YOU SA10, RIGHT 7 (AGAIN, THE JURY i
__NOT PRESET, THUS, REGARDLESS OF THIR-RESPONSE
OR TESTIMONY 1T_IS IMPoSsiBLt To_ASCERTALN HOW”
THIS WOULD HAVE AFFECTED THE TURY'S VERDICTS

FURTHER, MS. TABLTHA RONEY WAS PRESENT DURING __

_ The GUILT iNocence Prase. BUT SHE WAS NOT

@ caren vlow), ;
_ Re: Vor3, PLZ PG.aI9 LINES $-10 “ANGELA BOTHWELL ” 7

PG, aal tides 12-14 “ANOLE YOU HADTESTIFIED EARLIER
_1S) FROMT_OF_A TURY DURING THE OTHER PART_OF THE
“TRiaL., You Would HAVE HAD To Bt Honest LIKE You
Just were; |S THAT RIGHT? (HERETO, ITLS. IMPORTADT
_To_Nore.7 THAT_MS, ANGELA BOTHWELL WAS ALSO PRESET
_ DURING THE OTHER PART-OF THE TRIAL (GUILT /inNocEeNce.

~-PAASE-) HOW és/2.8 SHETo ules Not CALLED UPon).

@_TuH: TRIAL COURTS FINDING AND. CONCLUSIONS Of. LAW
__ AS WELL AS THE | STATE'S Rt sPonst ARE THAT THE