gha/wa
Court of Criminal Appeals 201 W 14th St,
Ausrin,rx 78701 l:,A-|-Ez M§V_ 11 z¢\§
. FlLE 1N wR T F:LE RECE@VED mt Paui Baiiey #01833_504 BY: o §§ : COURT OF CRWAL Ap;¢wq
J ames Lynaugh Umt
1098 south Highway 2037
ron stockton, Tx 79735 NDV O 9 2015 11/4/15
Re: WR-80,640-02 ' ' Abet Acosta, Cllert<
I am writing to provide a copy of the Forensic Document Expert's Report that verified that State's Exhibit 7 used by the Collin County District Attorney, Greg Willis, was in fact a forgery. Please ensure that this letter and the accompanying documents are entered into the court record.
Not only was the audio on the tape “criminally altered” (as covered more than adequately in the Writ of Habeas with all expert reports attached (that should NOT have been ruled on by the Court of Appeals because of the incomplete record at the trial court)- but 2 pieces of key evidence used 1n my prosecution were FORGED. If the case was strong enough, why tamper with audio and forge signatures?
Once again, Regarding the incomplete record, the following issues that must be dealt with at the trial court level in accordance with Holmes v South Carolina:
l) Objection to Attorney Affidavits (I have emails showing they lied m their affidavits, thus committing a fraud on the court)
2) Motion to Vacate Void/Default Judgment(s) Once again, the Trial Court must also deal with these issues:
l) Officer Scott Greer has been Dishonorably Discharged and banned from testimony in Denton and Collin Counties_
2) Audio was tampered with as verified by no less than 5 experts and the erased section from the lapel mic Was retrieved from the car audio was performed and verified by 2 experts
3) State‘s Exhibit 7 was verified as a forgery of Deceased Detective Debra Stansell's signature by a Forensic Document Examiner.
4) Current news regarding the Attorney General Paxton indictment raised issues that the Collin County District Attorney Greg Willis has denied documents meant for the Grand Jury. Has this been an ongoing issue? And what internal controls are in existence to ensure defendants documents make it to the Grand Jury?
Such a denial sets forth an act that deliberately violates defendant's due process, neglecting the relevant issues entirely. A complete court record is not discretionary and cannot be dismissed in any manner as clearly stated in Supreme Court‘s ruling Holmes v South Carolina. ln addition, my right to confront my accusers in a courtroom is also not discretionary according to the Constitution.
I declare under penalty of perjury that the foregoing is true and correct. Respectfully Submitted
PAIJL CLARENCE BAILEY, Pro se TDCJ #1833504
J ames Lynaugh Unit
1098 South Hig`hway 2037 Fort Stockton, TX 79735
Paul Clarence Bailey, Pro Se
Date ///“////F
CER'I`IFICATE OF SERVICE I certify that a correct copy of this document has been forwarded to Counsel , in accordance with Federal Rules of Civil Procedure on this day of , 2015 as follows
`Via' U.s.rzs CemM Deliverv
f _’ Court of CriminalAppeals P.O. Box 12308 Austin, Texas 78711
: Collin County District Attorney Creg Willis
.2100 Bloomdale Rd Suite 100 McKinney, TX 75071
w_w.'li' eriDo'cume'/it£)'camm
CURT BAGGETT
Expert Document Examiner 908 Audelia Road, Suite 200-245, Richardson, TX 75081 Phorie: 972.644.0285 - Fax: 972.644..5233 cbhandwriting@_g@il.com Www.ExpertDocumentExaminer.com
Curt Baggett is a leading handwriting expert in the United States. He is also a skilled authority in
` document examination and as an expert witness and he has completed over 5.000 cases. Mr. Baggett has examined documents and/or testified in court cases as a handwriting expert in all 50 states, Washington, D.C., the Bahamas, Brazil, Canada, Chile, England, Ireland, Mexico, Pakistan, Puerto Rico, Thai.land and Ncw an|and, `Korca, China, Australia and Denmark.
The U.S. Department of Justice, the State of A_rizona, State ofArkansas, the State of California, Louisiana Public Defender Board, and the State of Texas have retained him. Mr, Baggett has appeared as a handwriting expert on WOLF-BLITZER-CNN; CHARLES GlBSON-ABC, INSIDE EDITION, CBS Network Radio, CBS, CNBC, CNN, FOX, JUDGE ALEX, TEXAS IUSTICE and GOOD MORNING TEXAS and was a consultant as a forensic document examiner for a number one television show, “CSI: Crime Scene lnvestigation”. Mr. Baggett is the co-author of "The Handwriting Ceitiiication Home Study Course” and “How To Spot a Forgeiy” and has been a guest on Various other television and radio programs discussing handwriting and forensic document examination
Mr. Baggett once held the position as Dean of the School of Forensic Document Examination at Handwriti.ng University. in addition to lecturing and teaching document examination, Mr. Baggett has analyzed handwriting for over 40 years He has been qualified as an expert witness in .lustice of the Peace, Municipal, District, State, U_S, District, and Federal Bankiuptcy Courts, Easteni Caribbean Supreme Court, High Court onynwald British lsles and the Provincial Courts of Canada.
H.is education and training in document examination and psychology include; U.S. Army, Military Police Officer’s School; B.A. and M.Ed., McNeese State University, Lake Charles, Louisiana; and post-graduate studies at the University of Houston, Houston7 Texas.
Cuit Baggett’s library is extensive and includes literature on questioned document examination, forensic handwriting analysis, behavior profiling, and statement analysis
Laboratoiy equipment used for examination consists of a Stereo Star Zoom American Optical 7x ~ 30x twin microscope; Micronta illuminated 30x microscope_; stereo microscope S/ST seiies; universal DigiScoping adapter; numerous magnifying devices; protractor and metric measuring devices_; Pentax ME camera; Pentax macro l..4, 50111111. flat copy lens; overhead projector; light table, and transparencies.
Curt Baggett’s Educatiou and Training in Handwriting and Document Examination Include:
An in person two-year apprenticeship with Dr. Ray Wall
The American Bureau of Document Examinei's ceitifies Mr. Baggett. l-le also has a certificate of completion from the Am_eri_can lnstitute oprplied Science.
l Re\-' 10/31/15
Lectures, Conferences, and Classes Attended:
2004 School of Forensic Document Examination"s Amiual Conference, Dal_las, Texas Attended classes taught by Reed l_~layes, QDE, Katherine _Koppenhaver_, QDE, Bill `Koppenhaver, QDE
2004 School of Forensic Document Examination’s Teleclass Ciu“riculum Examination ofAnonymous Writing by Reed Hayes, QDE Document Examination Terminology by Don Lehew, QDE Notary Public by Don Lehew, QDE Advanced Forgeiy ldentification by Don Lehew, QDE lnstiuctor
2005 School of Forensic Document Examination’s Annual Conf`erence, Dallas, Texas Attended the following lectures, in addition to general sessions: Tremors and line Quality taught by Reed Hayes, QDE . Demonstrative Evidencc taught by Katherinc Koppenha'vcr, QDE, Bill Koppenhaver, QDE Photography through microscopes by David Babb, QDE Paper and Watermarks by John McGuire, QDE Lecturer
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gha/wa
Court of Criminal Appeals 201 W 14th St,
Ausrin,rx 78701 l:,A-|-Ez M§V_ 11 z¢\§
. FlLE 1N wR T F:LE RECE@VED mt Paui Baiiey #01833_504 BY: o §§ : COURT OF CRWAL Ap;¢wq
J ames Lynaugh Umt
1098 south Highway 2037
ron stockton, Tx 79735 NDV O 9 2015 11/4/15
Re: WR-80,640-02 ' ' Abet Acosta, Cllert<
I am writing to provide a copy of the Forensic Document Expert's Report that verified that State's Exhibit 7 used by the Collin County District Attorney, Greg Willis, was in fact a forgery. Please ensure that this letter and the accompanying documents are entered into the court record.
Not only was the audio on the tape “criminally altered” (as covered more than adequately in the Writ of Habeas with all expert reports attached (that should NOT have been ruled on by the Court of Appeals because of the incomplete record at the trial court)- but 2 pieces of key evidence used 1n my prosecution were FORGED. If the case was strong enough, why tamper with audio and forge signatures?
Once again, Regarding the incomplete record, the following issues that must be dealt with at the trial court level in accordance with Holmes v South Carolina:
l) Objection to Attorney Affidavits (I have emails showing they lied m their affidavits, thus committing a fraud on the court)
2) Motion to Vacate Void/Default Judgment(s) Once again, the Trial Court must also deal with these issues:
l) Officer Scott Greer has been Dishonorably Discharged and banned from testimony in Denton and Collin Counties_
2) Audio was tampered with as verified by no less than 5 experts and the erased section from the lapel mic Was retrieved from the car audio was performed and verified by 2 experts
3) State‘s Exhibit 7 was verified as a forgery of Deceased Detective Debra Stansell's signature by a Forensic Document Examiner.
4) Current news regarding the Attorney General Paxton indictment raised issues that the Collin County District Attorney Greg Willis has denied documents meant for the Grand Jury. Has this been an ongoing issue? And what internal controls are in existence to ensure defendants documents make it to the Grand Jury?
Such a denial sets forth an act that deliberately violates defendant's due process, neglecting the relevant issues entirely. A complete court record is not discretionary and cannot be dismissed in any manner as clearly stated in Supreme Court‘s ruling Holmes v South Carolina. ln addition, my right to confront my accusers in a courtroom is also not discretionary according to the Constitution.
I declare under penalty of perjury that the foregoing is true and correct. Respectfully Submitted
PAIJL CLARENCE BAILEY, Pro se TDCJ #1833504
J ames Lynaugh Unit
1098 South Hig`hway 2037 Fort Stockton, TX 79735
Paul Clarence Bailey, Pro Se
Date ///“////F
CER'I`IFICATE OF SERVICE I certify that a correct copy of this document has been forwarded to Counsel , in accordance with Federal Rules of Civil Procedure on this day of , 2015 as follows
`Via' U.s.rzs CemM Deliverv
f _’ Court of CriminalAppeals P.O. Box 12308 Austin, Texas 78711
: Collin County District Attorney Creg Willis
.2100 Bloomdale Rd Suite 100 McKinney, TX 75071
w_w.'li' eriDo'cume'/it£)'camm
CURT BAGGETT
Expert Document Examiner 908 Audelia Road, Suite 200-245, Richardson, TX 75081 Phorie: 972.644.0285 - Fax: 972.644..5233 cbhandwriting@_g@il.com Www.ExpertDocumentExaminer.com
Curt Baggett is a leading handwriting expert in the United States. He is also a skilled authority in
` document examination and as an expert witness and he has completed over 5.000 cases. Mr. Baggett has examined documents and/or testified in court cases as a handwriting expert in all 50 states, Washington, D.C., the Bahamas, Brazil, Canada, Chile, England, Ireland, Mexico, Pakistan, Puerto Rico, Thai.land and Ncw an|and, `Korca, China, Australia and Denmark.
The U.S. Department of Justice, the State of A_rizona, State ofArkansas, the State of California, Louisiana Public Defender Board, and the State of Texas have retained him. Mr, Baggett has appeared as a handwriting expert on WOLF-BLITZER-CNN; CHARLES GlBSON-ABC, INSIDE EDITION, CBS Network Radio, CBS, CNBC, CNN, FOX, JUDGE ALEX, TEXAS IUSTICE and GOOD MORNING TEXAS and was a consultant as a forensic document examiner for a number one television show, “CSI: Crime Scene lnvestigation”. Mr. Baggett is the co-author of "The Handwriting Ceitiiication Home Study Course” and “How To Spot a Forgeiy” and has been a guest on Various other television and radio programs discussing handwriting and forensic document examination
Mr. Baggett once held the position as Dean of the School of Forensic Document Examination at Handwriti.ng University. in addition to lecturing and teaching document examination, Mr. Baggett has analyzed handwriting for over 40 years He has been qualified as an expert witness in .lustice of the Peace, Municipal, District, State, U_S, District, and Federal Bankiuptcy Courts, Easteni Caribbean Supreme Court, High Court onynwald British lsles and the Provincial Courts of Canada.
H.is education and training in document examination and psychology include; U.S. Army, Military Police Officer’s School; B.A. and M.Ed., McNeese State University, Lake Charles, Louisiana; and post-graduate studies at the University of Houston, Houston7 Texas.
Cuit Baggett’s library is extensive and includes literature on questioned document examination, forensic handwriting analysis, behavior profiling, and statement analysis
Laboratoiy equipment used for examination consists of a Stereo Star Zoom American Optical 7x ~ 30x twin microscope; Micronta illuminated 30x microscope_; stereo microscope S/ST seiies; universal DigiScoping adapter; numerous magnifying devices; protractor and metric measuring devices_; Pentax ME camera; Pentax macro l..4, 50111111. flat copy lens; overhead projector; light table, and transparencies.
Curt Baggett’s Educatiou and Training in Handwriting and Document Examination Include:
An in person two-year apprenticeship with Dr. Ray Wall
The American Bureau of Document Examinei's ceitifies Mr. Baggett. l-le also has a certificate of completion from the Am_eri_can lnstitute oprplied Science.
l Re\-' 10/31/15
Lectures, Conferences, and Classes Attended:
2004 School of Forensic Document Examination"s Amiual Conference, Dal_las, Texas Attended classes taught by Reed l_~layes, QDE, Katherine _Koppenhaver_, QDE, Bill `Koppenhaver, QDE
2004 School of Forensic Document Examination’s Teleclass Ciu“riculum Examination ofAnonymous Writing by Reed Hayes, QDE Document Examination Terminology by Don Lehew, QDE Notary Public by Don Lehew, QDE Advanced Forgeiy ldentification by Don Lehew, QDE lnstiuctor
2005 School of Forensic Document Examination’s Annual Conf`erence, Dallas, Texas Attended the following lectures, in addition to general sessions: Tremors and line Quality taught by Reed Hayes, QDE . Demonstrative Evidencc taught by Katherinc Koppenha'vcr, QDE, Bill Koppenhaver, QDE Photography through microscopes by David Babb, QDE Paper and Watermarks by John McGuire, QDE Lecturer
2005 School of F orensic Document Examination"s Teleclasses Natural Vaiiation taught by Reed Hayes, QDE The Discrimination of Handwriting by Don Lehew, QDE Procedures for Examining Signatures by Don Lehew, QDE Courtroom Procedures and Roles by Don Lehew, QDE lnstructor
2006 School ofForensic Document Examination’s Annual Conference, Dallas, Texas Attended the following lectures, in addition to general sessions: Deposition and Cross Examinations by Dr. Richard Frazier, QDE Medical Problems Affecting handwriting by Dr. Richard Frazier, QDE Legal lssues for Document Examiners by Dr. Richard Frazier, QDE Deposition and Cross Examinations by Dr. Richard Frazier, QDE Health Factors Affecting Handwriting by Dr. Joe Alexander, QDE Prescription Forgery and Medical Crimes by Diane King Lecturer
2007 Handwriting University Annual Conference, Dallas, Texas Trainer and Instructor
2007 School of Forensic Document Examination’s Teleclasses Instructor - Handwriting Basics and Exemplars
lnstructor - Multiple Classes on Case Studies and Examinations
2008 Handwiiting University Annual Conference, Las Vegas, Nevada Trainer and Instructor
2009 School of Forensic Document Exarnination’s Live Teleclasses Attended a variety of classes taught by Robert Baier, QDE, Police lnstructor
2009 Handwriting University Annual Conference, _Las Vegas, Nevada
Critical incident Stress: Statement Analysis and lnterview v, interrogation by Faith Wood _Forensic Document Exainination Application by Robert Baier, QDE, Police Instmctor Ti'ainer and lnst:ructor for lntroduction to Forensic Document Examination
2010 Handwriting University Annual Cont`erence, Las Vegas, Nevada Advanced Statement Analysis by `Faith Wood ldentity Thef`t and Prevention by Robert Baier, QDE, Police instructor 'l`rainer and lnstructor for lntroduction to Fore1isic Document Examination
2010 Speaker _ “lntroduction to the Science ofHandwriting and Forensic Document Examination"`, Clear Lake High School
2011 Lecturer and Instructor, “How to Spot a Forgery”, Denver El.ections Division, Denver, Colorado
2012 Lectm'er and instinctor, “How to S’pot a Forgery”, Denver Elections Division, Denver, Colorado
2012 Speaker - “How to Avoid a Forgeiy”, Military Order of Puiple Hearts Annual Meeting, Dallas, Texas
2013 Speakei' - “lntroduction to the Science of Handwriting and Forensic Document Examination”; Appointment as Guest Lecturer and Consultant by Stefanie Page, Instrnctor, Forensic Science Department, Jesuit College Preparatory School of Dallas
2013 Speaker - “lntroduction to the Science ofHandwriting and Forensic Document Examination”, irma Lerma Rangel Young Women"s Leadership School, Dallas, '_l`exas
Past and Present i\'lemberships
American College of Forensic Examiners International _Ameiican Legion
Center of Forensic Profili_ng
Forensic Expert Wimess A.ssociation
IMS Expeit Services
Military Order of World Wars
National Questioned Document Association Sheriff’s Association of`Texas
Texas Police Association
Veterans of Foreign Wars
World Federation ofHandwriting Expeits
National Association ofDi_stinguished Professionals SEAK-Expert Directory
Published Articles and Books
Ethics for Experts
Handwiiting Certifi.cation Coui'se
How to Help Attorneys With Your Case How to S'pot a Forgeiy
Tal
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