Baladez, Sandro

• Court: Court of Appeals of Texas
• Decided: March 26, 2015
• Docket: WR-82,775-01
• Status: Published

Opinion

IN THE COURT OF SANDRO BALADEZ, Petitioner vs. § 01 NO. -Ree~1~eo IN THE STATE OF TEXAS § COURT OF CRIMINAL APPEALS MOTION FOR REHEARING TO THE HONORABLE JUSTICE OF SAID COURT: MAR 26 2015 Comes now SANDRO BALADEZ, (petitioner) in the above~style and~entitled cause and respectfully files this "Motion For Rehearing" pursuant to T~~~~g~t~, Qle~/k Appellate Procedure, Rule 79.1., inresponse to the Court of Criminal Appeals March 04, 2015 judgment of the denial without written order of petitioner Application For 11.07 Writ of Habeas Corpus (Case No. 01-1-6242-A) which the following statement and legal issue:s are in support of petitioner motion.

l. Petitioner contends that he was deprived of equal protection of laws, Due Process, State and . State and Federal Constitutional laws because;

2. Appellate counsel W.A. (Bill)White didn't "adequately" raised the argument concerning the "Facts" on direct appeal ground of "Insufficiency of Evidence" that comes inform of State witnesses (Faisai Pirzada, Terry Grewe and Tim Nie- lson) fabrication of hearsay not in compliance with Miranda warnings state- ments that falsified their testimonies to establish "direct and circumstantial evidence" before the jury that impaired the Jury deliberations and verdicts that illicited petitioner illegal conviction, which this ground deserve to be entertained by the Court of Criminal Appeals thoroughly;

3. Appellate counsel didn't. raise on direct appeal the denial of effective assistance of trial counsel whom prosecuted petitioner in 1998 as a Juvenile and whom failed to apprise petitioner and or the trial court of his juvenile assistant district attorney employment and prosections of petitioner (Actual Conflict of Interest) that motivated counsel to act as a prosecutor against petitioner in petitioner closing arguments sessions of the murder trial.

4. "Petitioner" did raised the 'foremention grounds of error in his 11.07 writ of Habeas Corpus. WHEREFORE, PREMISES CONSIDERED, petitioner requests that this Honor- able Justice(s) grant petitioner motion due to the foremention!

,state o f : £ o a t e : ~dfj/j

. Beaumont, Texas 77705

CERTIFICATE OF SERVICES I hereby certify that a true and correct copy of the foremention "Motion For Rehearing" has been nailed to the illURT OF CRIMINAL APPEALS OF TEXAS, Clerk; Abel Acosta, P.O. BOX 12308, Capitol Station, Austin, Texas 78711, on this If; , of ~eft ,2015. IN THE COURT OF CRIMINAL APPEALS OF TEXAS SANDRO BALADEZ, § Petitioner vs. § Criminal Case No. 01-1-6242-A

THE STATE OF TEXAS § COURT ORDER

The foregoing "Motion For Rehearing" presented to the Honorable Justice of said Court is hereby:

GRANTED:

DENIED:

Signed, this: ;day of: --------------- ------------------;2015.

/s/ PRESIDING JUSTICE