APPEALS No.WR-82,974-01 

TRIAL.Ct.No-2010-426,671-A 

KEENON JONES 

Appellant 

§ 

§ 

RECEIVED IN 

COURT OF CRIMlNALAPPt:AlS 

COURT OF CRIMINAL ~ 

APPEALS OF TEXAS JUl 17 

v. 2il15 

THE STATE OF TEXAS §'· P.o.Box 123os,cAPITOL sT~@fAcosta, Clerk 

AUSTIN,TEXAS ~8Yll 

APPELLANT"S PRO-SE MOTION FOR A WRIT OF MANDAMUS,WITH THE 

TEXAS RULES OF ALLELLANT PROCEDURE and GROUNDS 

With ORAL ARGUMENT IN SUPPORT THEREOF. 

To The Honorable Clerk,Abel Acosta, 

Comes Now,~eenon Jones,TDCJI1825082,CID,Alfred D.Hughes Nnit 

Rt 2 Box 4400/,3201 FM 929 Gatesville,Texas 76597. 

Appellant asserts to this Honorable Court of Criminal Appeals 

that he didnot filed any Reconsideration Hearing,on his Appeal,he 

file,An Unreso~ved "ISSUES" ! "NOT",Requesting any Reconsideration 

at this time because of his Records. 

Appellant arg~es his reasons for this OBJECTION,is that with~ 

out his "Phone Call","Records", ! ,HE CAN NOT FILE HIS RIGHT DUE 

PROCESS OF LAW,and his well to the point arguments and his vi~lations of his "constitutional Rights",which at this tt~e haved 

been violated,under T.he Six and Fourteenth Amendments. 

Appellant asserts and argues that he did send a letter motion 

to his Lawver and to the court reporter and he did not get any 

answer from thoi~ Officials. 
Appellant is arguing these facts that he has found newly discovered evidence because of this Honorable Court rulings on this 

his Writ of Habeas Corpus.This Rule of T.R.A.P.Rule 79.2(d)states; 

T.R.A~P.Rule 79.2.(d) A motion for rehearinq an order ·',~.: 

that denies habeas corpus relief under code of Crimi~~ 

nal Procedure,artiales 11.07 or ll.07l.May not be fi~ 

led.The Court may on its own initiative·reconsider 

the case. 

Appellant did filed an Notice of Appeal and this court of 

Appeals takes it ass an Motion for reconsideration,this Notice of 

Appeal does not state anything about "YOUR COURT", tr.'6 Reconsider, 

this Writ of Habeas Corpus ll.07,it stated unresolved issues. 

Please See State Ex Rel.Holrnes V.Kleven Hagen cite as 

819 s.w.539 Tex.cr.App.l99l)pg [l]As previously noted, 

the state now seeks relief by writ of Mandamus to cornpie Judges to rescind her order granting Williams habeas. conpus relief and to direct the Harris County 

sheriff to excute the Governor's Warrant.Pursuant to 

Art.V,§ S,of the Texas Constitution,this Court has 

jurisdi~tion to issue Writs of rnandarnus.It is wellsettled by this Courti·.that in order for mandamus to 

issue,the party seekung mandamus must show that theFe 

is no other adequate remedy available and that the act: 

sought to be cornplelled is a ministerial act.Brayton 

V.Dunn,803 S.W.2d~3]8,320,(Tex.cr;App.l99l) ,citing 

State exrel.Holrnes v.salinas,780 s.w.2d 216 (Tex.cr. 

App.l990),and Stearnes V.Clinton 780 S.W.2d 216 (Tex. 

Cr.App.l990) •. :tll<·' ::;;·_,1 .. 1' :·:; 

Appellant asserts and argues that if his Lawyer and the Court 

Reporter never send his copies of that of what he order from them, 

then it is not his f~ult,because he due diligently seeked these 

records.Please See; 

Dean v.state cite as 900S.W.2d.367(Tex.App.-Texarkana 

l995)pg 369[1] If an Appellant has made a timely request for a staernent of facts,but the court reporter's 

notes and records have been lost ordestroyed without 

the appellant's fault,he is entitled to a new trial 

unless the parties agree a statement of facts.Tex.R." < 

App.P.SO(e).The party seeking relief must show that 

he made a timely request for the statement of facts 
and that,without any faul~ of his,the reporter's notes 

have been lost or d~stroyed. 

Appellant asserts that on this Ruled of Appellant Procedure 

§ 44.0l.(a)The state is entitled to appeal an order of a 

court in a criminal case if the order; 

Appellant argues that his first prong,on this Writ of Mandamus 

that this court went straightt~1the point of sendinq appellant to 

ari avenue of wanting him to file an Motion for recorisider~tion, 

~hen in this case law it states this;Please See; 

819 S.W.539 n.at 541 [2i3)As to the first prong,relator contends he has no other adequate remedy at law 

because the State has no right to appeal a judgment 

granting habeas corpus relief unless that judgment 

may be construed .as' an order granting a new trial. 

See Art.44.0l,V.A.C.C.P.Ordinarily,a respondent in a habeas 

corpus case cannot appeal from. a jud~ment discharging ~ 

the app~icant.state v.Gonzales ,459 s.w.2d 947(Tex. 

Civ.App.-San Antonio,l970,no writ). 

Appellant also· aigues that if his law would haved send him 

all .. his records it would have been a differsnt out come on him 

and .on his filing to this court his right due process of law. 

See 900 S.W.2d 367,n.at.369(Tex.App.-Texarkana 1995). 

369[4]Nevertheless,when an appellant is deprived of a 

statement of facts.he is entitled to a new trial irrespective of harm.Sheffield V.State,supra.Dean's failure to show or even ~llege.~a defect or in adequacy in 

the warrent does not cure the error.Dean v.state.Supra. 

Appellant asserts that he is requesting all his documents of 

his case,"The Phone Calls•.that were used to convicted him.or 

all the DNA Testing records if there were any in his case,the 

lawyer never showed him any records of this kind at any time. 

Rule 44.01. (3)grants a new trial; 

Rule 44.01.(6)is issued under chapbet 64. 

Appellant is also requesting the DNA Testing that was done on 

his case and claim at this time. 

4. 

,,· 
PRAYER 

I1Keenon Jones prays that this Honorable Court of Appeals of 

ITexas will Grant this Motion of Appellants request for this beening argu~d in a very short time1to argue1because of lock down in 

this Unit and dorms. 

CERTIFICATE OF SERVICE 

I,Appellant c~rtify that a copy of this pro-se motion was 

sent to this Honorable Court of Appeals of Texas P.O.Box 12308/·' 

Capitol Station Austin1Texas 78711/by u.s.postage and is adding 

the prison mail box rule1and is requ~sting that this court will 

send copies to all partys involved and that. this court will Grant 

this motion,and that it will conduct a Evidentiary Hearing and 

that appellant is under penalty of periurv and that a of the 

above is true and correct to the best of his knowledge and that 

all relief will be sought in his case and claim. 

Texas Gov't Code1Civil Practice Remedy/132 28 u.s.c. § 1746. 

Executed on ehis 15 day of July 2015. 

Respectfully Submitted 

Keenan Jones #1825082 

Alfred D.Hughes Unit 

Rt 2 Box 4400//3201 FM 

929 Gatesville1Tx 76597. 

Respectfully Submitted 

7-15-15 
' . 

KEENON JONES 

Appellant 

v. 

APPEALS No.WR-82,974-01 

TRIAL.Ct.No.2010-426,671-A 

COURT OF CRIMTNAL 

APPEALS OF TEXAS 

THE STATE OF TEXAS §<)p';;'O.Box 12308,C?\PITOL STATION 

AUSTIN,TEXAS 78711 

Appeals From The 

140TH Judicial District 

County Courthouse 

Lubbock,Texas 

APPELLANT"S PRO-SE MOTION OBJECTING TO THE DISMISSAL DECISION 

OF THE RULING DATED,6-15-2015,PURSU~NT TO ~HE 

TEXAS RULES OF APPELLANT PROCEDURE RULE 79.2(d). 

And Adding Oral Argument To The Hold Rule of 

T. R. A. P. Rule 79. Rehearings,( 79.1 )Motion For Rehearing, 

(79.2.)Contents. In Addition With A 

WRIT OF MAND~MUS,BEENING THE SUBPLEMENTARY GROUND, 

FOR THIS "OBJECTION". 

VERNON"S CONSTITUTION OF THE STATE OF TEXAS ANN 

nrticle V.Judicial Department Section § S.Jurisdic~ 

tion of Court of Criminal Appeals;terms of Court; 

Clerk.Sec. S.(a),(b),(c). 

VERNON"S TEXAS STATUTES ANNOTATED 

6.Code of Criminal Procedure 

Article 44.01.[812],[893],[871] Appeal by state