131
MR. JASON T. PEGUES #728196 HUNTSVILLE UNIT 815 12th STREET HUNTSVILLE, TEXAS 773&8
reh/wqu 092,, 201 5
cc/file:
TO; COURT OF CRIMINAL APPEALS BOX 12308 CAPITOL STATION AUSTIN, TEXAS 78711_
RE: Ex Parte JASON TYRONE PEGUES
cAUSE No;9a-DcR-026185 Hca
DEBR MADAM/SIR:
,_?H" '7(.02"0'-/
CORECEWED E?\E
COURT OF CF{IMNAL APPEALS FEB 05 2015
AWACMC§@¢<
PLEASE FIND ENCLOSED A NOTICE TO THE COURT BY THE APPLICANT IN
REFERENCE TO THE ABOVE MENTIONED CAUSED NUMBER.
IF YOU WILL PLEASE
PLACE THE ENCLOSED TN THE FILE 0F SAID CAUSE NUMBER SO THAT IT MAY BE
PRESENT AND TAKEN INTO CONSIDERATION UPON RULING THE CURRENT APPLICATIOB
THANK YOU FOR YOUR TIME AND ASSISTANCE.
THE APPLICAN
°#ZZY/%e
1#728196
cause no.94-DCR-026185 HCA
1 of_l
-wR-74,762-03
CAUSE N0.94-DCR-026T85 HC&
IN_THE COURT OF CRIMINAL APPEALS
Ex parte
JASON T. PEGUES IN
AUSTIN, TEXAS
000£00<00<0!¢0°¢01003¢0>¢0>¢0)¢0)609
* NOTICE TO THE COURT *
TO THE HONORABLE JUDGE OF SAID COURT:
THE APPLICANT,JASON T. PEGUES #728196, WOULD LIKE TO BRING TO
THIS HoNoRABLE coURT's ATTENTION THE FoLLowING so THAT THE APPLICANT wILL'NoT FALL UNDER"_ABUSE 'oF wRIT, As wELL As BRIl\IGIN.c-'l NoTIcE To THE coURT THAT THE APPLI¢ANT'$ SUBSEQUENT APPLICATION Is UNDER THE UMBRELLA oF HIS INITIAL APPLICATIoN(wR-7a,762-03,'wHIcH wAs DENIED wITHoUi wRIiTEN 0RDER oN Aggg§;_gligglg). THIs sUBsEQUENT
APPLICATION IS PURSUANT TO RULES OF APPELLATE PROCEDURE,RULE79.2(d),
WHICH IS ALSO IMPLEMENTED IN THE SUBSEQUENT'S MEMORANDUM, REQUESTING AND SUGGESTING THIS HCNORABLE COURT TO REVIEW THE CONSTITUTIONAL LEGITAMACY OF THE APPLICANT'S CONVICTION, AS THE APPLICANT CHALLENGES
THE JUDGEMENT OF SENTENCE IN CAUSE NO.26185,(EX parte MORENO,Z&S S.W13d
I.
THIS SUBSEQUENT APPLICATION PRESENTS NEW CREDIABLE, CRITICAL,
CLEAR and CONVINCING EVIDENCE THAT WAS NOT AVAILABLE BEFORE APPLICANT'S INITIAL APPLICATION WAS FILED, WHICH IS ALSO LEGALLY IMPLEMENTED IN
THE NATURE OF PROCEEDING OF THE SUBSEQUENT'S MEMORANDUM, CONTAINING
;*l l
SUFFICIENT SPECIFIC FACTS ESTABLESHING THAT THIS NEW EVIDENCE WAS
`NOT AVAILABLE BEFORE APPLICANT'S INITIAL APPLICATION WAS FILED, THE
NEW EVIbENCE WILL PRdVE BEYOND A REASONABLE DOUBT THAT APPLICANT'S SUBSTANTIAL RIGHTS PURSUANT TO FEDE§AL RULES OF CRIMINAL PROCEDURE(SZb) WERE AFFECTED AND HIS CONSTITUTIONAL RIGHTS WERE VIOLATED ALONG WITH. FAMILY CODES AND PARENTAL NOTIFICATION REQUIREMENTS. DUE TO THIS NEW EVIDENCE AND SUPPORT BY STATE, FEDERAL, AND SUPREME COURT, THE- APPLICANT CAN ASSURE THAT REVIEWING AND ADJUDICATING THE MERITS OF
THE APPLICANT'S CLAIMS AND ISSUES IN THIS CASE WILL NOT BE A 'Q
WASTE OF THIS HONORABLE COURT'S TIME, FULLY RESPECTING AND PURSUANT TO RULES OF APPELLATE PROCEDURE, RULE 79.2(d), VERNON'S ANN.TEXAS C.C.P.
art.11.07 (EX parte MORENO, 245 S.W.3d 419 (TEX.CRIM.APP.ZOO8).
II. THE REsPoNDENT RESPoNDED oN g§g§g§§§_ggigglg, AND THE APPLICANT
RECEIVED THE RESPoNDENT's ANswER oN gé§g§§§_liggl§, AND IMMEDIATELY
JTHE APPLICANT OBJECTED. ATTACHED TO THIS NOTICE IS A COPY OF THE
APPLICANT oBJEcTING To THE RESPoNDENT's ANSwER wHIcH wAs FILED oN gé§gégg_§£giggl§, AND wouLD LIKE To ALSo sHow THIS HoNoRABLE coURT THE FoLLowING so THAT THE APPLIcANT_wILL NoT FALL UNDER- ABUSE oF wRIT(Ex parte MARTINEZ 233 s.w.3d 319 (TEX.cRIM.APP.2007).=
THE APPLICANT'S FIRST Two APPLICATIONS wERE PERTAINING To PRE-SENTENCE JAIL-TIME cREDIT. THE APPLIcANT'S THIRD APPLICATION IN wHIcH UMBRELLA'S THIS SUBSEQUENT APPLICATIGN, ls BASED oN THIS HONORABLE coU§T