Ellington, Peter John

• Court: Court of Appeals of Texas
• Decided: August 20, 2015
• Docket: WR-83,709-02
• Status: Published

Opinion

§§,';I”OQ 'U]/OH CEWED\N

MUNDAY, AususT 17, 2015 @§m-QF(;RMNALAPPEALS AUB.ZO 2015

Mr. Ahel Acosta, Elerk Eourt of Criminal Appeals

P.o. au><_'\zzoa, capitol station A@@§A@@§ia,@q@@‘

Austin, TX 78711

RE: writ Applications, CEA Eause No's UR-03,709-(01 and 02). Trail Court No.'s 0416-02711-09-(HE1 and H02)

Dear Mr. Acosta,

Early this morning (00:20 A.M.) l picked up from the prison legal mail room two "Mhite_Eard" notices informing me that the Eourt of Criminal Appeals had re- ceived my two (2) 11.07 writ Application‘s from the h16th District Eourt on Aug. 7th, 2015. l believe this was an error on the h16th District Bourt's part.

l received on July 2hth, 2015 a Memorandum and URDER from Judge Ehris Uldner of the 416th District Court, telling me he was ordering affidavits to be filed by August 20th (he had allowed 60 days, but my envelope was NOT mailed from the EOurthouse until July 21st and l received it on July 24th, a full month after it was signed by the Judge.). Judge 01dner had found four (h) points of error, con- troverted previously unresolved issues that could in fact overturn my wrongful conviction. I don't know why the Court forwarded my 11.07 Applications to your

EUurt without first finding the FAETS the Judge had already noted as unresolved.

Therefore, l am sending you a MOT10N and Suggestion‘s for the Honorahle justices's of the Bourttof Criminal Appeals to remand the writ's (11.07'3) BACK to Collin Eounty and the h16th Court and to hold my Application's of Habeas Eorpus 11.07'3 in ABEVANEE until the previously indicated unresolved issues can be re-

solved.

~,¢.. , ._.- ~- , ..

y Please FILE These papers with the EUURT, and bring them to the IMMEDIATE attention of the Honorahle Judges as this is a TIME SENSITIVE IBSUE.

ps Could you PLEABE send me a SlncerElY yours’

copy of this letter l am sending -

you with a File Stamp for my

records? l am inclosing a copy Peter J Ellington, 019234

for you to return to me. CT Terrell Unit 1300 FM 655

Thank you & God Bless. Rosharon’ TX 77585

MONDAY, AUGUST 17, 2015

or. Aool Arooro, clark (:%7?9. _ Court of Eriminal Appeals 07 : be//

P. 0. Box 12308, Capitol Station Austin, TX 78711 f H»'u.M.

RE: writ Applicetions, CCA Cauee No‘s wR-83,709-(01 end DZ). jTrail Court No.'s wh16-BZ711-09-(HB1 and HBZ)

.}Deaerrr;Acosts, 7 ;.:,`),y -

` _ Early this morning (DB: 20 A. M. ) I picked up from the prison legal mail room f ”Q§two "Hhite Card" notices informJB% me that the Eour$ of Criminal Appeals had re-

J'“f ceived my two (2) 11.07 writ Applicatton's from the h16th District Bourt on Aug. `*" 7th, 2015.1 believe this w an error on the h16th Dietrict Court's part§

0\ I received on~lu§;-éggh'l21 5 s Memorandum and DRDER from Judge Chrie'Dldner of

the h16th District Court, telling me he was ordering affidavits to be filed by August 28th (he had allowed 60 days, but my envedope was NOT mailed from the Courthouse until July 21st and I received it on July 24th, a full month after it .was signed by the Judge.). Judge Dldner had found f§zrr (h) points of error, con- tooverted previously unresolved issues that could in fact overturn my wrongful conviction. I don't know why the Court forwarded my 11.07 Applications to your Court without first finding the FABTS the Judga had already noted as unresolved._

H_ Therefore, I am sending you a MOTION and Suggestion's for the Honorable gustices' s of the Cour¢tof riminal Appeals t remand the writ's (11. 07's) BAEK to'\'.`.ollinl County~:and them w§(rw\ §§ 11§07'o*dn ABEvANcs until the previously indicated unresolved issues ron oo.ro-

Eourt end to my Applica'tion l 8 of Habeq”a:wcorp_ua,_, M. .

_-;;' sierra FILE Tnooo'poporo with the couRT, and bring than to the IMMEDIATE attention of the Honoreble Judges as this is a TIME SENSITIVE ISSUE.

Sincerely yours,

ps Could you PLEASE send me a copy of this letter I'am sending you with a File Stamp for my records? I am inclosing a copy Petsr Joh llington, # 819234 for you to return to me. CT Terrell Unit

1300 FM 655 Thank you & G°d 918€9- Roonoron, Tx 77533

CAUSE N0.'5 wR-BZ-709-(01 AND 02) TRIAL ET. ND.'S wh16-82711-09-(HE1 AND'HEZ)

EX PARTEW §L'EUURT UF ERIMINAL APPEALS PETER JUHN ELLINGTUN¢ § (Applicant) § § AUSTIN, TEXAS §

METIDN AND`SUBBESTIBN T0 THE'CUURT Df"ERlMINAl'APPEAES T0 REMAND'BACK T0 THE TRIAL CUURT FOR THE RESULUTIUN 0F PREVIUUSLY CUNTUVERTED ISSUES

T0 THE JwDEES 0F THE CDURT 0F ERIMINAL APPEALS:

'EDMES N0w, Peter John Ellington, Applicant'Pro Se in the above styled and numbered cause, who moves this 00urt of Eriminal Appeals -to hold his Habeas Eorpus Application in Abeyance and Remand to Trial Eourt for the development of previously controverted factst ` l.

(a) 0n April 2hth, 2015 Applicant filed (by mailbox.rule) his two Application‘s for writ of Habeas Eorpus (11.07's) with the u16th District Trial Eourt. File Stamped on May h, 2015. n

(b) The Elerk served the instant writ on the D.A. (State) on May 1Bth, 2015.

(c) n 0n May 16th, 2015 l (Applicant) realized l had accidently for- gotten to include my "GRUUND FOUR" pages 12 & 13 with the writ Appli- cations. l immediately prepared a MOT10N T0 AMMEND.and included the missing pages 12 & 13 Eround Four "Prosecutorial Misconduct", and explained why l had not sent them in the original packages. Eopy

was sent to the State (Eollin County DA). l was not able to send the MOT10N and attached Eround.Four because I was unable to get any post-

'age Stamps until May 21st when I mailed it ( and filed it per mailbox

rule). The Eourt and DA received this within 72 hours of the DA recei_

_1_

ving the Instant writ from the Clerk's 0ffice.

(d) - nn gone 2nd, 2015 tno stoto tilod it'oinoooonoo to ny writ Applicatiom; but ignored the "GRUUND FO0R" pages 12 and 13,1 had asked them to include and had filed a Motion for the same;

(e) 0n June Bth, the same day I received the State's Response l sent/filed by mailbox rule a Motion for NOTIEE and EXTENSIUN of TlME to file a reply/traverse to the State's.Responset

\

(f) 0n June 16th, l filed a MOT10N for Interogatories. f.

(g) 0n Jume 24th, l filed my REPLYZTRAVERSE/;p£the State's Re- sponse with Attached Exhibits PRDVINB my claims in my writuApplications. (h) 0n July 16th 2015 l filed a MOIl0N for and EVIDENTARY Hearing. (i) 0n JuhQLZAth, 2015 Judge Ehris 01dner, 416th Judicial District Court Signed and Filed a Memorandum and 00DER as to the finding of previously unresolved issues of controverted allegations in my writ(s). (SEE Attached EXHIBIT # 1)} The 0RDER is for the submission of the Affidavits from myself, my Eourt (Triali Lawyer, and the State. The Judge gave 60 days + to comply, by August 20th, 2015. NOTE: The CUURT 'did not mail my copy until the 21st day of :nJL &End l received it Dn ;E£:L£/ZA, 2015 a FULL MUNTH after it was 0RDERED!`That was a Friday.

§§va 21,20{§ ' (j)_ on MondoyAi rent/filed o MoTloN and o Lottor to dodge oldnor and a second Motion asking for the additional 30 days he had meant to give me in the 0riginal 0rder, making the Affidavitsndue on SeptL 2Bth, 2015. And the 5econd Motion for an Evidentairy Hearing`and the Appointment of Counsel, per Art. 11.09 EBP. The First Motion was the

Notice of Appeal and Request for Extension of Time to File the

0rdered Affidavits. See EXHIEIT"S 2a-e.

(k) 0n August 7th, 2015 the CUURT cf ERIMINAL APPEALS had now

'_2_

received my two (2) Application's for writ of Habeas Eorpus (11.07) from the Trial Eourt without the Trial Eourt's findings of their own admitted previously controverted (four issues) facts that l had reaise in my Application. By`the Judge's own DRDER he had given all parties to the 20th day of August to submit the Affidavits and" actually in the interest of Justice and Fairness should have appro- ved the MOT10N for EXTENSION of TIME and reset the deadline until the 20th of Septembery 2015, because of the ERROR in NOTIFYINE me 30 days late. Il. The Trial Court has not responded to any Request's or Motions

l have filed as a Pro Se Applicant who is indigent, has lost all con-

tact with my family and my firends since being wrongfully convicted

for a crime that never happened and of which l AM lNNUCENT UF-

The Eourt 01D NOT acknowledge my "GRUUND FO0R" Prosecutorial Misconduct" pages 12 & 13, and neither did the State in their Response to my 11.07 Application's. n

. My Reply to the State's response seems to have fallen on deaf ears, and more importantly;-the District Court has now forwarded my two writ Application's to the EEA without making the indicated as per 0RDER, the resolution of the indicated unresolved controverted issues of fact. n PRAVER

1 PRAY that tnia Moat Reaoootad coort, the Honoraolo Judgaa for the E.E.A. will APPRUVE this MOT10N & SUEGESTlUN_to REMAND this ~back to the Trial Court for the resolution of the previously controa verted issues and extend the time until at least the 28th of 5epti

2015 to submit affidavits, if l can even do that by that date. l would

_5_

pray that you would see how important an evidentary hearing is in this particular case, and ensure in the intrest of justice and fair- ness that I be granted an Evidentiary Hearing in Person, to CRDSS examine my Attorney‘s (all three) of Record with out the ASSISTANCE of the District Attorney, and with Appointment of Eompetent Counsel to assist in this matter. NOTE: l never had a TRIAL, l was coerced into pleading guilty to get a 5 year deffered probation, and l did not want to do even that. l paid my lawyer for a JURY-TRIAL, and she refuesd to do that. l am in prison for life without parole basically for a crime that NEVER TO0K PLAEE.

Please HOLD my Application in AEEVANEE until the issues are

resolved.

Respectfully yours,

\QQMQLQMW S}n/)i

Peter John Ellington #101923h ,ET Terrell Unit

1300 FM 655

,Rosharon, TX 77503

uNswoRN DEcLARATIoN I, Inmate Peter John Ellington, TDEJ #1019234, Incarcerated in Brazoria

County Texas, Declare under penalty of perjury that the above statements are true and correct, to the best of my knowledge and belief.

P ter J Ellington B/17/2015 EERTIFICATE 0F SERVICE Dcerhfythat a TRUE and CURRECT carbon Eopy of the foregoing Motion & Suggestion has been sent to the Collin County District

Attorney by placing same in the Prison 05 MAIL BUX on this 17th day of August, 2015 P05TAGE T0 PE PROVIDED BY LAw LIBRARY INDIGENT MAIL

~P ter 3 n Ellington, Mo£e

PER TDEJ POLIEY for INDIGENT Prisoners.

EAUSE N0.'s wR-B3-709-(01 and 02)

Ex PARTE § 'couRT oF chMlNAL APPEALS PETER JUHN ELLleTuN' § y 'Appllca"t _ ' § AusTIN=TEXAs § __9§§§§-a CAME EEFURE This Eourt on the *”# .Day of , 2015, The

Pro Se Motion and Suggestion to Remand to the Trial Court,ApplicantVs

11.07 Application of writ of Habeas Corpus in both styled and Numbered

Causes above this Eourt hereby 0RDER5:

That the Applications for 11.07 be remanded back to the

Trial Eourt to resolve the previously indicated issues

of previously controverted issues. GRANTED _ DENIED That Applicant will have until September 28th, 2015 to submit Affidavits to support his claims of Ineffective Assistance of Eounsel.' `GRANTED ' ' ’ DENIED

That an Evidentary Hearing is indicated in this case to allow the facts and truth to be made fact in the record and to allow for the Applicant to have a fair and just

hearing to develop this record-in the intrest of JUSTIEE. GRANTED ' ' DENlED

By the Eourt

Proprosed 0RDER 3udge Presiding

. - / - ‘i’? ;~w'll@l \ \ l _ - 1 time l / aa a _ _ ;;a;»)“//z¢{l)§)` @/Mm In The 416"' Judicialnis¢rirz Cour¢, faa

Collin County, Texas Honorable Chris 01dner, hesiding

Cause Nos. W4I6-82711-09(HC)

Ex Parte P£t_er John Ellinan

Memorandum

. The Court, having received the Application for a Writ of Habeas Corpus and the State’s response, makes the following iinding:

A controverted, previously unresolved issue exists as to the allegations contained in the application, to wit:

l. Ground Three: Ineffective assistance of counsel., Specilically;

a. Alleged failure to “explain anything” concerning pleas, prison, parole [sic];

b`. Alleged “promise” to applicant that he would receive probation, or no more than‘iive years;

c. Alleged “overbearing my will” of applicant and forcing him to “lie to the Court” by pleading guilty;

d. Alleged refusal to take case to trial.

'l'he State and the applicant are ORDERED to submit aHidavits responsive to these issues on or before the 28th clay of August, 2015. The applicant’s trial attorney is ORDERED to submit an affidavit responsive to this issue on or before the 28ul day of August, 2015. The Court will also review and consider the Reporter’s Record from the

open plea. ' v Signed the 24th day of June, 2015. /V y . \ t f/€_\ chds\oldao/r \/ V -

Judge Presiding`

M EDIO

TO: Honorable Presiding Judge of the 4lbth Judicial District Court of Collin County,State of Texas

RE:HABEAS CORPUS #:W4l6-827ll-O9(HC)

SUBJECT(S): l)APPEAL/REQUEST as to Extension ot Time to File Artidavits Z)MOTION for the Appointment/Recruitment of "Counsel".

Dear Honorable Judge, How can I Cross Examine a Piece Of Paper,,Or Even have

an Opportunity to Give My Rebbttal to it. I have included numerous Exhibits

fin Document Form as to What Transpired Between My Attorney and I. But there

is TESTIMONY available should she DISPUTE My Ground as to Ineffective Assis- tance of Counsel. That is why l filed for an EVIDENTIARY HEARING,which is provided for in the Article ll.O7 C.CRIM.PROC Procedures by the Fact Finder Judge. I Respectiully Request that your allow me an EVIDENTIARY HEARING with i

My Appearance being handled by a Standard Bench Warrant.

Additionally,Please take note of the APPEAL/REQUEST that I just filed. I just got your ORDER on July 24th,2015=A Friday. For me to be able to do what you have instructed I really NEED all the Time that you intended me to have. Why the District Clerk's Office SAT on the ORDER for a Month,is beyond my comprehension,when the Judge was ORDERING a Time Limit to Do Something. I know TEX.R;APP.PROC 29.5 allows the COURT to Withdraw and Reissae£the€ORDER being complained about in the Appeal.l have enclosed with the APPEAL/REQUEST a Proposed Order to Quickly and Easily resolve this issue.

I have also submitted a MOTION for the Assistance of Counsel as : a)Provided for in the Article 11.49 Lanquage and/or b)As the Court would deem appropriate. Can you please RULE on the Submitted MOTION5/i REQUESTS and Ensure that the District Clerk' s Office Mails them back to me \

in a Timely Manner? ' v \\ Thank You for Your Time and Attention to these Matters

Res ectfull Submitted By

szévwz,bw yes/ff Peter John Elli gton,Pro Se. C. T. TERRELL UNIT /- #1819234

1300 F. M. 655 Brazoria ROSHARON , EXAS 77%%§

wild 7/2?//9”

CC:API*

omit/rae

TO:COLLIN COUNTY DISTRICT CLERK'S OFFICE ATTN:COURT CLERK for the 4l6th JUDICIAL DISTRICT COURT

RE:HABEAS cAsE #: w4lo-82711-09(Hc)

SUBJECTLS): 2 FILING_ 1 ; No'rrce or APPEAL ana REQUEST FoR sx'l'nNsroN or TIME To FILE 2) MoTIoN,PURsUANT To ARTICLE 11.49-TExAs cons or cRIMINAL PROCEDURE FoR THE APPOINTMENT / RECRUITMENT or "ooUNsEL" To "omnn ama"dnmmnm"inmtmtmmnnriccnsnnALtmmmzHAs donna l GREETINGS,

Enclosed Please Find the TIME SENSITIVE Pleading as Described

Above. - "Jh Can you please FILE TMEM and Bring Them To The Court's Attention as

Soon as Possible for its Ruling and Action.

Thank You for Your Time and Attention to these Matters

Res ecttull Submitted By

7/ZS’//( P ter John Elli gton,Pro Se

HCJT.TERRELL UNlTn/-#1819234 1300 F.M.b§b (Brazoria Co) ROSHARON , TEXAS 77583

row / pan en ta malley 7121/)-(

CC:File Copy

-.ev

W4lb-827ll-O9(HC)

§ IN,THE DISTRICT coURT or Ex PARTE PETER JOHN ELLINGTON § COLLIN COUNTY,TEXAS § 416th JUDICIAL DISTRICT _____________________________________ _§______________________________________ 0 n n c R

HAVING COME to the Attention Ot ThiS Court the APPLICANT'S PrO Se MIICE OF APPEAL and REQUEST FOR EXTENSION OF TIME TO FILE and Previous Filed MOTION FOR

AN EVIDENTIARY HEARING,ThiS COurl; Hereby ORDERS:

135 4 THAT THE AMENDED DATE TO HAVE AFFIDABIT(S) FILED I§€§;§g§§zéth,ZOl§

That an EVIDENTIARY HEARING is Scheduled for the DATE OF ZOlb,with the APPLICANT to_Appear by Standard Bench Warrant,To Be Issued

7 Days before the HEARING DATE to Ensure His Appearance.

That The APPLICANTS Request for an EXTENSION OF TIME TO FILE is DENIED and the APPLICANT should proceed in accordance with the Texas Rules of

Appellate Procedure.

sr THE coURT

JUDGE-PRESIDING

Propssed Order

,.

B`;

HABEAS CASE #: W416~827ll-O9(HC)

§ IN THE DISTRICT COURT or EX PARTE_PETER JoHN ELLINGTON § COLLIN`COUNTY,TEXAS § 4l6th JUDICIAL DISTRICT

PETER JOHN ELLINGTON the APPLICANT -'€.Pro Se),GiveS NOTICE OF APPEAL/ Pursuant to TEX.R.APP.P. 26.2(a)(l),ln Which He APPEALS the Trial Court's ORDER of 6/24/15 Reguiring Him to Submit Affidavits by August 23th,2015-as

to Justify the Ground in His Habeas Corpus Application. . In Addition To or

__ _1oiar_.111a. 11)1>11_<:1111:_ __raooa_.ata-,_th_a t. the ._.D'..UE DA.T`E..i.il>i_ste.n.d,€-f§..ir_sm.. 8/ 28/_2,£5_1 t09/29/2015,by virtue of the FACT that he Did NotFRECEIVE the ORDER until July 24th,2015-and it was Post Marked as MAILED to Him on July let,2015. ((See EXHIBIT l-ORDER,,and EXHIBIT 2-THE ENVELOPE IT WAS MAIL ED.))

n l Although ~the ORDER issued from the Trial Court was SIGNED June 24th,2015,APPLICANT did not Receive the ORDER until July 24th,2015-See:TEX.R.APP.P. 412(a)(l)

WHEREFORE PREMISES CONSIDERED,APPLICANT Formally GiveS NOTICE OF APPEAL, and Reguests that the Court ,Per TEX.R.APP.PROC 29.5 change the DUE DATE from 8/23/2015 to 9/23/2015.

Re?£ectfully Submitted By

e

Pe §¢§oM/`fin;gt;z, Pro Se

C.T.TERRELL UNIT/-#1819234

1300 F.M.655(Brazoria Co)

ROSHARON / TEXAS 77583 UNSWORN DECLARATION:

I,Inmate Peter John Ellington,TDCJ #:1819234,Incarcerated in Brazoria County,Texas,-Declare Under Penalty Of Perjury,that the Above

Statemets are True and Correct,To the Best of His Knowledge and Belief // - BY= @§ZM 63¢%@1€/ ZY//§

CERTIFICATE OF SERVICE PE R J HN ELLIN TON,PRO SE I CERTIFY that a True and Correct COPY of the Foregoing APPEAL/REQUEST was SERVED by lst Class Mail upon the Collin County District Attorney's Office on

_ July 27th,2015. BY: fw 7/27//§

Peter John llington,pro Se

HABEAS CASE #: w416-82711-09(HC)

§ IN THE DISTRICT COURT OF EX PARTE PETER JOHN ELLINGTON § COLLIN COUNTY,TEXAS § 4l6th JUDICIAL DISTRICT §

‘MOTION,PURSUANT T0 ARTICLE 11.49-TEXAS CODE OF CRIMINAL PROCEDURE ' FOR THE APPOINTMENT / RECRUITMENT OF "COUNSEL" n TO "OPEN" and "CONCLUDEn The ARGUMENT,-UPON TRIAL UNDER HABEAS CORPUS NOW COMPES THE APPLICANT,Peter John Ellington-LPro Se),Who Respectfully MOVES this Court to Appoint or Recruit Counsel for Him to Handle,At Minimum, the OPENING and CONCLUSION of Any and All Trials or Hearing heald Under the nAQSQiCQ§WQ§iHl§lHABEA§_§QBBHSNAPPLlQATlON= In_SupPQrL_I"Represent to the Court:

1)In Article ll.49 of the Texas Code of Criminal Procedure,It States: OHMLLOF ARGUMENT...THE APPLICANT SHALL HAVE THE RIGHT BY HIMSELF OR COUNSEL TO OPEN

AND coNcLUDE THE ARGUMENT UNDER THE/UPON*THE”TRIAL uNDER HABEAS coRPUS.

2) It would be in thel INTERESTS OF JUSTICE for the APPLICANT to have the Assistance ot an Attorney to Bring Forth The FACTS Regarding His HABEAS CORPUS GROUND to the Trial Court/Fact Finder Judge.

3) The APFLICANT has MOVED the Court to ahe an EVIDENTIARY HEARING (Instead Or ln Addition to the Submission of Affidavits) and the Issuance of Subpoena(s) and/or Subpoena(s) Duces Tecum(s) will be REQUIRED,Thus the ASSlstance ot an Attorney would be beneficial to the Court and the Applicant.

WHEREFORE PREMISES CONSIDERED,Applicant PRAYS that This Honorable Court~ In the Interests ot Fairness,Justice and Etficiency Appoint / Recruit an Attorney for the Matters Under/Upon Trial ot Habeas Corpus.

Respecttully Submitted By

Peter John Ellington,Pro Se

C.T.TERRELL UNIT /-#1819234

l3UU F.M.obb (Brazoria Co)

ROSHARON , TEXAS 77563 UNSWORN DECLARATION:

I,Inmate Peter John Ellington,TDCJ #21819234,Incarcerated in Brazoria County,Texas,-Declare Under The Penalty of Perjury that the Statemets in the Foregoing MOTION are True and Correct,To The Best Of My Knowledge and Belief.

EXECUTED on JULY 25th/2015 BY . CERTIFICATE OF SERVICEPeter John Ellington,Pro Se I CERTIFY that a Trune and Correct COPY of the Foregoing MOTION was SERVED

by lSt Class Mail on July 27th,2015-(Mail Box Rule) Upon the COLLIN COUNTY

DISTRICT ATTORNEY'S OFFICE. BY. 'Peter John Ellington,Pro Se

.1 EW\@W;BF .

W4l6-827ll-09(HC)

§ IN THE DISTRICT COURT OF EX PARTE PETER JOHN ELLINTON § ‘. COLLIN COUNTY,TEXAS § * - §§ 4l6th JUDICIAL DISTRICT 0 R D E R §§§i‘i&£====:= CAME BEFORE This Court on the Day of ,2015, The Pro Se

MOTION,PURSUANT TO ARTICLE ll.49-TEXAS CODE OF CRIMINAL PROCEDURE,FOR THE APPOINTMENT /

RECRUITMENT OF "COUNSEL" TO "OPEN" and "CONCLUDE" The ARGUMENT¢~UPON TRIAL UNDER HABEAS

“GIHUSL This Court,having Reviewed The Law and Precident(s) Hereby ORDER:

THAT ATTORNEY ‘ IS COURT APPOINTED/RECRUITED TO

ASSIST THE APPLICANT , . TO OPEN AND CONCLUDE ARGUMENT

TO ASSIST WITH HOUSEKEEPING MATTER LIKE SUBPOENA(S) and AFFIDAVIT PREPARATIONHETC

AS IS REASONABLE FOR SUCH ADVERSARIAL - PROCEEDING

THAT THE APPLICANT'S MOTION FOR "COUNSEL" IS DENIED

BY THE COURT

Proposed Order