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MR. TDCCI:
I AM HGPING YOU HAVH FILED 303 AN INVESTIGATOR FOR MY CABES. 83 E$EED ?ICTURES 03 THB FRONT 03 THE HOUSE AT 153 HOLLIDAY PLUS THE DRIVEWAY GF THE HOUSE AND ?ICTURBS 03 TH,E BACK 03 THH HQUSB IN APARTMENT# 3 W8ICH IS A SMALLER HOUSE 83333 I ACTUALLY LIVED, FQR CAU3F d 3597 AGG A3S AULT 8/ D3ADLY 83APOH, AND 3U3PO3NA THE PLUMB3R HR. BARNES FROM 13b PRIORITY PLUMBIHG. “
18 CAUSE# CR-2293, FELGN IN POSSEBION 03 FIRF ARH, 83 83 33 AN INVESTIGATOR TD GET- TRAFFIC CITATIONS THAT OFFICER RAMOS , WROTE IN BR? WEEN THE ,HDURS 03 93 OOQM 333 io;OOpm, IT WILL PROVE . 83 WAS NQT GGING NGRTH 08 FRESA BUT WERE WRITING CITATIGNS 30
ANQTHBR vEHchF BEFQRE THEY ser BEHIND 03 ON ran NIGHT 09 Nov 9 9, 201£, PLUS ANQTHER chATIom HE waowe MF 03 omnEn TRAFF c £[)3 swain me usgs savoy sum mg w \~,A=soea,A Ar.so.subpoa\@v¢ ‘_’Qum\\ OSIAS DC\\)e\r
83 NEED A MOTICN TQ QUASH INDICTMBNT, A HOTION 303 GASKIN MATERIAL, A MOTION 303 BRADY MATERIAL, A MOTION 303 EVIDF HCE _FAVORABLH TO DEFENDANT, A PRETRIAL HEARING MOTION'AND DIF COVERY MOTIONS. I NEEB ¥OU TO SIGN 98 8¥ MEMORANHUM IN SHPPQRT 03 333 MOTIQN TQ SUPPREBS IN CAUSE§ CR~2293 FELGN IN ?03833108 FIREARM, ATTACKING THE STOP SEARCH AND NEGLECT 03 DUTY PURF UAHT ARTICLE 2. 03 QF THE TEXA$ CGDE OF CRIMINAL PRQCFDURE, BECAHSE THE OFPICER ON THB PASSENGF 3 SIDE DID NGT WRITE REPORT, DUE PRQCESS VIGLATIGN
83 NBED MOTION TO DISMISS INSUFFICIENT 3VIDENC3, A MOTIQN TO DISCOVER THE CRIMINAL 33 QCORD 93 WITNEBS, A MGTIGN 303 GASKIN :MATERIAL g A MQTION 303 BRADY MATERIAL, A MOTIGN 30 QUABH v INDICTMENT, AND A MGTION TO SUPPRESS. I NEED YOU TQ BIGN 08 TQ MY MEMORANDUM IN SUPPQRT 03 THB MDTION TO SU?PRESS, ATTACKING `THE RECKLESS DISREGARD OF TRUTH 18 SEARCH WARRANT AFFIDAVIT IN CAU.3 33 CR~3597¢
wa HAVE wAIsTED 50 DAYS ALBBABY AND MY DEFENSE 15 BECQMING IMPA;RED. z HAVE ALL oF THBQE ABOVE MQTIGNS QN FILH AL&BABY PRQ sE, PLEASE vISIT ME 30 wz cAN coME To Aw AGREEMENT ow gow 83 ARE selma To FIGHT MY CASES.
PLHASE DGNT FDRGET ABQUT THE INVESTIGATOR¢
THANK YOU!!
y 33 ECT ULLY¥Y , 101 l . MMM.:Q YC/
;._IME:`LDA¥~ %GUEROP\ qAYMgrqz) DA.NIF,LS
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OCTOBER~l-IZ
DEAR HONORABLE JUDGE MELISA SKINNER:
I MET WITH MY»ATTORNEY JAMES V. TOCCI FOR THE FIRST TIME AUGUST 3, 2012, HE TOLD ME HE WOULD VISIT ME 2 WEEKS FROM AUGUST 3, 2012, BUT HE NEVER SHOWED UP. MY NEXT COURT DATE WAS ON SEPTEMBER 21, 2012, HE WASNT THERE AND I WAS RESET UNTIL SEPTEMBER 25, 2012, HE SHOWED UP AND I EXPRESSED MY CONCERNS ABOUT MY DEFENSE BEING IMPAIRED BECAUSE I NEED AN INYESTIGATOR TO TAKE PICTURES OF ALLEGED CRIME SCENB, LOCATE 2 WITNESSES AND ALSO GET SOME KIND OF RECORD OF TRAFFIC CITATIONS WRITTEN IN ANOTHER CAUSE. I HAVE 2 ALLEGED FELONY.OFFENSES IN 290th DISTQ;QT COURT, CAUSE# CR-2293, CR 3597, l NEED WITNESSSES SUbP§§S§§§ IN BOTH CASES. l KNOW MR. TOCCI IS A GOOD ATTORNEY HE MAY BE REALLY BUSY WITH ®THBR CLIENTS. NOW MY COURT DATE IS SET FOR NOVEMBER 9th, 2012, I NEED THE INVESTIGATOR TO BE WORKING NOW BECAUSE M¥ INNOCENCE-IS BECOMING IMPAIRED, WE HAVE WASTED 50 or 60 DAYS AND WHEN NOVEMBER 9th GETS HERE 100 OR MORE¢ I HAVE MOTIONS ON FILE PRO SE AND MEMORANDUMS I NEED MY ATTORNEY TO SIGN ON THEM. AT THIS POINT HE HAS ONLY FILED 1 MOTION AND I CANNOT¢GO TO TRIAL WITHOUT CERTAIN MOTIONS BECAUSE
I WILL HAVE NOTHING TO PRESERVE ERROR IN THE EVENT OF APPEAL.
THANK IQU FOR BOTH YOUR TIME AND EFFORT!!
RESPECTFULLY:
w \05>%7~
RAYMOND DANIELS SID# 358196 OCTOBER-1*12
§§ §
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THE sTATE 0F TEXAS` IN THE DISTRICT coURT - VS ~ 290th JUDICIAL DISTRICT RAYMOND DANIELS JR. BEXAR COUNTY TEXAS
TO THE HONORABLE JUDGE OF SAID COURT:
MY NAME IS RAYMOND DANIELS JR ,THIS is my second letter to you_ regarding my concern of my defense becoming impaired,my court dates have been AUGUST 3rd 2012 ,september let 2012 september 25 2012,NOVEMBER 9th 2012,and i have a court date set now for JANUARY 25th 2013,at this point my attorney JAMES V TOCCI HAS yet to a§Kthe court for an investigator for boud\of my criminal cases cause no.2011cr2293, CAUSENOCR 3597,ihave witnesses that need to be subpeonaed in both cases also in causenocr2293 i need pictures of intersection and record of previous traffic citation written by officer felipe ramos ,incausenocr3597g§
in causenocr3597 i need pictures of residents at 158 halliday front house and back house where i actually live.
l lo ls thankyou
- IMELDA FiC-UERO%, '
` fog §CE §:;.%.::; NoTARY PuBLlc ‘/l;/ - ,.-'a,.-‘ sTATE oF TEXAS
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POLlCE REPORT
z¢;v;§@i San Antonlo °"@"S°Cas°# ~* § SAPD11281979 Po| lee Offense Descr|ptlon FELON POSS F|REARM Date l Tlme Occured 11/9/11 9:51 pm to 11/9/11 9:51 pm
Offense Locatlon C|ty ` State le
3600 S. PRESA SAN ANTON|O TX
Report|ng Off|cer Name Badg
RAMOS, FEL|PE 0206
‘ N_'arjn'§ 1 ` nos Age
DAN!ELS, RAYMOND ` v 05/02/1965 46 _v _ t 02an Aqdre§§: 158 HALL|DAY AVE SAN ANTON|O TX 78210
Name DOB Age
ROSAS, JUAN 07/07/1964 47
Name DOB' Age
Year . Nlake ' Mode|
1995 CHEV BER
- Type Descrlptlon Brand Mode| Co|or
»w..=.'_
Page 1 of 2
1113 " . "`)
NARRAT|VE
On the listed date and time I was on patrol with (Wl). (Wl) and I were both in a marked police vehicle while in full police uniform. We were traveling north on S. Presa when the listed vehicle darted
out from Halliday (westbound) and made a v_eg;g_gi_§l;;ight turg_ (north) onto s. Presa. The vehicle . completely w the posted stop sign at the listed intersection. I had to slam on my brakes to avoid
colliding with the suspect vehicle. The vehicle also had a light dangling from its reaiptha_tT/v;§__`_'L covering the lettering of the rear license plate. Due to the traffic violations we activa ed our overhead lights
and conducted a traffic stop of the vehicle at the listed location. As (Wl') and I walked up to the vehicle,
Free access — add to your briefcase to read the full text and ask questions with AI
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Q`M$D -'
' .' \` ‘-' s 24 ' _ _ dow 1 1 l
0€T03ER~?-2013 " ,
.)
MR. TDCCI:
I AM HGPING YOU HAVH FILED 303 AN INVESTIGATOR FOR MY CABES. 83 E$EED ?ICTURES 03 THB FRONT 03 THE HOUSE AT 153 HOLLIDAY PLUS THE DRIVEWAY GF THE HOUSE AND ?ICTURBS 03 TH,E BACK 03 THH HQUSB IN APARTMENT# 3 W8ICH IS A SMALLER HOUSE 83333 I ACTUALLY LIVED, FQR CAU3F d 3597 AGG A3S AULT 8/ D3ADLY 83APOH, AND 3U3PO3NA THE PLUMB3R HR. BARNES FROM 13b PRIORITY PLUMBIHG. “
18 CAUSE# CR-2293, FELGN IN POSSEBION 03 FIRF ARH, 83 83 33 AN INVESTIGATOR TD GET- TRAFFIC CITATIONS THAT OFFICER RAMOS , WROTE IN BR? WEEN THE ,HDURS 03 93 OOQM 333 io;OOpm, IT WILL PROVE . 83 WAS NQT GGING NGRTH 08 FRESA BUT WERE WRITING CITATIGNS 30
ANQTHBR vEHchF BEFQRE THEY ser BEHIND 03 ON ran NIGHT 09 Nov 9 9, 201£, PLUS ANQTHER chATIom HE waowe MF 03 omnEn TRAFF c £[)3 swain me usgs savoy sum mg w \~,A=soea,A Ar.so.subpoa\@v¢ ‘_’Qum\\ OSIAS DC\\)e\r
83 NEED A MOTICN TQ QUASH INDICTMBNT, A HOTION 303 GASKIN MATERIAL, A MOTION 303 BRADY MATERIAL, A MOTION 303 EVIDF HCE _FAVORABLH TO DEFENDANT, A PRETRIAL HEARING MOTION'AND DIF COVERY MOTIONS. I NEEB ¥OU TO SIGN 98 8¥ MEMORANHUM IN SHPPQRT 03 333 MOTIQN TQ SUPPREBS IN CAUSE§ CR~2293 FELGN IN ?03833108 FIREARM, ATTACKING THE STOP SEARCH AND NEGLECT 03 DUTY PURF UAHT ARTICLE 2. 03 QF THE TEXA$ CGDE OF CRIMINAL PRQCFDURE, BECAHSE THE OFPICER ON THB PASSENGF 3 SIDE DID NGT WRITE REPORT, DUE PRQCESS VIGLATIGN
83 NBED MOTION TO DISMISS INSUFFICIENT 3VIDENC3, A MOTIQN TO DISCOVER THE CRIMINAL 33 QCORD 93 WITNEBS, A MGTIGN 303 GASKIN :MATERIAL g A MQTION 303 BRADY MATERIAL, A MOTIGN 30 QUABH v INDICTMENT, AND A MGTION TO SUPPRESS. I NEED YOU TQ BIGN 08 TQ MY MEMORANDUM IN SUPPQRT 03 THB MDTION TO SU?PRESS, ATTACKING `THE RECKLESS DISREGARD OF TRUTH 18 SEARCH WARRANT AFFIDAVIT IN CAU.3 33 CR~3597¢
wa HAVE wAIsTED 50 DAYS ALBBABY AND MY DEFENSE 15 BECQMING IMPA;RED. z HAVE ALL oF THBQE ABOVE MQTIGNS QN FILH AL&BABY PRQ sE, PLEASE vISIT ME 30 wz cAN coME To Aw AGREEMENT ow gow 83 ARE selma To FIGHT MY CASES.
PLHASE DGNT FDRGET ABQUT THE INVESTIGATOR¢
THANK YOU!!
y 33 ECT ULLY¥Y , 101 l . MMM.:Q YC/
;._IME:`LDA¥~ %GUEROP\ qAYMgrqz) DA.NIF,LS
FKNARYPUBUC gcTOBvR_;;zoj? i~»TATE O'F TEXF\S
g any Comm. EXP- 02 11 2015 120%1
v`,V\/vv\yv\l
vvvv
¢ vvv"v~"
3333 ' ' »
OCTOBER~l-IZ
DEAR HONORABLE JUDGE MELISA SKINNER:
I MET WITH MY»ATTORNEY JAMES V. TOCCI FOR THE FIRST TIME AUGUST 3, 2012, HE TOLD ME HE WOULD VISIT ME 2 WEEKS FROM AUGUST 3, 2012, BUT HE NEVER SHOWED UP. MY NEXT COURT DATE WAS ON SEPTEMBER 21, 2012, HE WASNT THERE AND I WAS RESET UNTIL SEPTEMBER 25, 2012, HE SHOWED UP AND I EXPRESSED MY CONCERNS ABOUT MY DEFENSE BEING IMPAIRED BECAUSE I NEED AN INYESTIGATOR TO TAKE PICTURES OF ALLEGED CRIME SCENB, LOCATE 2 WITNESSES AND ALSO GET SOME KIND OF RECORD OF TRAFFIC CITATIONS WRITTEN IN ANOTHER CAUSE. I HAVE 2 ALLEGED FELONY.OFFENSES IN 290th DISTQ;QT COURT, CAUSE# CR-2293, CR 3597, l NEED WITNESSSES SUbP§§S§§§ IN BOTH CASES. l KNOW MR. TOCCI IS A GOOD ATTORNEY HE MAY BE REALLY BUSY WITH ®THBR CLIENTS. NOW MY COURT DATE IS SET FOR NOVEMBER 9th, 2012, I NEED THE INVESTIGATOR TO BE WORKING NOW BECAUSE M¥ INNOCENCE-IS BECOMING IMPAIRED, WE HAVE WASTED 50 or 60 DAYS AND WHEN NOVEMBER 9th GETS HERE 100 OR MORE¢ I HAVE MOTIONS ON FILE PRO SE AND MEMORANDUMS I NEED MY ATTORNEY TO SIGN ON THEM. AT THIS POINT HE HAS ONLY FILED 1 MOTION AND I CANNOT¢GO TO TRIAL WITHOUT CERTAIN MOTIONS BECAUSE
I WILL HAVE NOTHING TO PRESERVE ERROR IN THE EVENT OF APPEAL.
THANK IQU FOR BOTH YOUR TIME AND EFFORT!!
RESPECTFULLY:
w \05>%7~
RAYMOND DANIELS SID# 358196 OCTOBER-1*12
§§ §
\IVVVVV
. <’z MELDA€HGUERGA ' '- NOTARY PUBLBC
; ST..@JC oe= TE)
¢” MyComm,ExpO241Q0?5
.I~/VVVVVV'VVV\/V
._,_(E‘\{\\'.\g_l”\ \C\
!*- )C\~~IB
THE sTATE 0F TEXAS` IN THE DISTRICT coURT - VS ~ 290th JUDICIAL DISTRICT RAYMOND DANIELS JR. BEXAR COUNTY TEXAS
TO THE HONORABLE JUDGE OF SAID COURT:
MY NAME IS RAYMOND DANIELS JR ,THIS is my second letter to you_ regarding my concern of my defense becoming impaired,my court dates have been AUGUST 3rd 2012 ,september let 2012 september 25 2012,NOVEMBER 9th 2012,and i have a court date set now for JANUARY 25th 2013,at this point my attorney JAMES V TOCCI HAS yet to a§Kthe court for an investigator for boud\of my criminal cases cause no.2011cr2293, CAUSENOCR 3597,ihave witnesses that need to be subpeonaed in both cases also in causenocr2293 i need pictures of intersection and record of previous traffic citation written by officer felipe ramos ,incausenocr3597g§
in causenocr3597 i need pictures of residents at 158 halliday front house and back house where i actually live.
l lo ls thankyou
- IMELDA FiC-UERO%, '
` fog §CE §:;.%.::; NoTARY PuBLlc ‘/l;/ - ,.-'a,.-‘ sTATE oF TEXAS
tg-.
.'.`5:."'..»' ' v w n l w .:{)_EO.F<€F.- Mycomm..Exp-OZ-"-?O"€’ l:¥ § §§ > 67 g
s: \/\:. \;9¢;&
¢_._ 227§] '_
l
POLlCE REPORT
z¢;v;§@i San Antonlo °"@"S°Cas°# ~* § SAPD11281979 Po| lee Offense Descr|ptlon FELON POSS F|REARM Date l Tlme Occured 11/9/11 9:51 pm to 11/9/11 9:51 pm
Offense Locatlon C|ty ` State le
3600 S. PRESA SAN ANTON|O TX
Report|ng Off|cer Name Badg
RAMOS, FEL|PE 0206
‘ N_'arjn'§ 1 ` nos Age
DAN!ELS, RAYMOND ` v 05/02/1965 46 _v _ t 02an Aqdre§§: 158 HALL|DAY AVE SAN ANTON|O TX 78210
Name DOB Age
ROSAS, JUAN 07/07/1964 47
Name DOB' Age
Year . Nlake ' Mode|
1995 CHEV BER
- Type Descrlptlon Brand Mode| Co|or
»w..=.'_
Page 1 of 2
1113 " . "`)
NARRAT|VE
On the listed date and time I was on patrol with (Wl). (Wl) and I were both in a marked police vehicle while in full police uniform. We were traveling north on S. Presa when the listed vehicle darted
out from Halliday (westbound) and made a v_eg;g_gi_§l;;ight turg_ (north) onto s. Presa. The vehicle . completely w the posted stop sign at the listed intersection. I had to slam on my brakes to avoid
colliding with the suspect vehicle. The vehicle also had a light dangling from its reaiptha_tT/v;§__`_'L covering the lettering of the rear license plate. Due to the traffic violations we activa ed our overhead lights
and conducted a traffic stop of the vehicle at the listed location. As (Wl') and I walked up to the vehicle,
(Wl) approached from the passenger side while I approached f_rom the'drivers. As I made contact with the
driver (SP1) I noticed he appeared to be visibly nervous. Whi|e I was speaking to the (SP1) I noticed the
passenger (AP1) was concealing'l_iis right hand into his open jacket. The (AP1) was asked to remove his
'~ hands and to place them on his lap for our safety. I asked the (AP1) for a form of ID and he advised me "_'t_hat_`__ he did not have any. The (AP1) then began to nervously dig into his pockets after he had already
e_d me that he had no form of ID. As the (AP1) was moving around and digging in his pockets I noticed he had nis left arm frm|y pressed up against his left side. His left arm was not moving as if he was event something flom falling out 'At thls~'~aint (‘.".12 an -."'l.'-B~‘ had arrived on scene to nrn\/ide.
1 " lc ver. Due to the way (AP1) was concealing his hand and the way he had his arm pressed on his side, _» ` `_(AP1) was asked to exit the vehicle to be frisked for weapons for our safety. As soon as (AP1) exited (W1) " began to frisk the (AP1) and immediately felt (E) inside the (AP1)'s right jacket pocket The (W)' s quickly
took (AP1) into custody without incident. The (AP1) was searched and then placed in our patrol car under arrest for felon possessing i"irearm. The (AP1) also had money on him in small stacks which is consistent with those involved in the illegal sale of narcotics. The (AP1)'s phone would not stop ringing and it had numerous messages for people asking for narcotics. The (SP1) was cited for the traffic violations and released. The (AP1) was transported to 401 S. Frio for booking and the (E) was placed in the SAPD property room.
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