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IN THE COURT OF CRIMINAL APPEALS OF TEXAS
TRIAL COURT CAUSE NO. 007-0396-03
TRIAL COURT WRIT NO. OO7-O396-O3-B
EX PARTE WILLIE RAY
MOTION FOR LEAVE TO PRESENT "WRIT OF ERROR CORAM NOBIS WITH MEMORANDUM IN SUPPORT"
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IN THE COURT OF CRIMINAL APPEALS OF TEXAS
TRIAL COURT CAUSE NO. 007~0396-03 TRIAL COURT WRIT NO. 007-0396-03-B
EX PARTE WILLIE RAY
MOTION FOR LEAVE TO PRESENT "WRIT OF ERROR CORAM NOBIS" WITH MEMORANDUM IN SUPPORT
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, WILLIE RAY, PRO SE MOVANT, IN THE ABOVE CAPTIONED AND NUMBERED CAUSES/ AND WOULD RESPECTFULLY REOUEST LEAVE TO PRESENT HlS "WRIT OF ERROR CORAM NOBIS" WITH MEMORANDUM IN SUPPORT; AND WOULD OFFER THE FOLLOWING:
I. JURISDICTION
THIS COURT HAS THE JURISDICTIONAL AUTHORITY TO HEAR AND cONSIDER HIS IN-STANT'WRI.T PURSUANT TO THE "ALL wRITS ACT 28 U.S.~C. §1651(a)."
II. STATEMENT OF FACTS
THE SMITH COUNTY DISTRICT CLERK RECORDS IDENTIFIES; "THE MOVANT FILED HIS INSTANT WRIT WITH THE COURT WITH MEMORANDUM AND EXHIBITS MARCH 27/2015 / [SEE ACCOMPANYING "WRIT OF ERROR CORAM NOBIS WITH MEMORANDUM AND ATTACHED EX-
HIBITS].
THE CLERKS RECORDS FURTHER IDENTIFIES THAT THE CLERK OF SMITH COUNTY/ FORWARDED THE WRIT TO THIS "COURT OF CRIMINAL APPEALS/" APRIL 08/2015/ [SEE
EXHIBIT-l ATTACHMENT]
THE CLERK'S RECORDS FOR THE COURT OF CRIMINAL APPEALS CLERK/"ABEL ACOSTA" , IDENTIFIES, JULY 7,2015/ THAT/ "THE ONLY WRIT EVER RECEIVED BY THIS COURT WAS, 'WRIT NO. WR-61-390-O4'", AN ART. §11.07 APPLICATION. THAT NO "WRIT OF CORAM NOBIS," WAS EVER RECEIVED BY THE COURT OF CRIMINAL APPEALS CLERK AT ANY TIME BEFORE,OR AFTER APRIL 08,2015 AS ATTACHMENT EXHIBIT-l IDENTIFIES TO THE MOVANT, THAT THE SMITH COUNTY CLERK/ LOIS ROGERS/ FALSELY PURPORTS ON A
STATE GOVERNMENTAL DOCUMENT.
ARGUMENTS:
THE MOVANT ARGUES THAT, THIS COURT SHOULD CONSTRUE THE SMITH COUNTY CLERK AS "INENTIONALLY, KNOWINGLY/WILLINGLY OR RECKLESSLY"ATTEMPTING TO MISLEAD AND CAUSE INJURY TO THE MOVANT BY STATING THAT SHE HAS PERFORMED AN ACT THAT SHE HAS NO INTENTION ON PERFORMING (FORWARDING THE WRIT TO THE COURT OF CRIMINAL APPEALS), SO THAT THE MOVANT MAY RECEIVE THE RELIEF HE IS ENTITLED UNDER THE PROVISIONS OF THE ALL WRITS ACT. AS WELL AS A COMPLETE DISREGARD
FOR HER PUBLIC SERVICE DUTIES AND OATH AS A CLERK/ UNDER THE CONSTITUTION.
THIS HONORABLE COURT SHOULD TAKE INTO CONSIDERATION THAT/ 'ON JULY 147 2015/ THE MOVANT AS WELL FILED A MOTION TO 7th JUDICIAL DISTRICT COURT OFSMITH COUNTY, TEXAS (i.e.'A MOTION TO COMPEL THE CLERK TO PERFORM DUTIES AND DELIVER THE WRIT TO THE COURT OF CRIMINAL APPEALS AS SHE INDICATED SHE DID). HOWEVER, THE 7tH JUDICIAL DISTRICT COURT REFUSES TO RESPOND TO THE MOTION PRESENTED, WHICH THE MOVANT' HAS A GOODFAITH REASON TO BELIEVE THE COURT IS ATTEMPTING TO AID AND ASSIST THE BADFAITH CONDUCT OF THE CLERK, BASED ON THE REASONABLE
FACTS AS DISCLOSED TO THIS COURT HEREIN.
WHEREFORE/ WITH THE FACTS AND EVIDENCE PRESENTED BEING FIRMLY ESTABLISHED ON THE FACE OF THE RECORD, THE MOVANT "WILLIE RAY" WOULD PRAY AND URGE THIS