Ex Parte James Richard "Rick" Perry
Opinion
&
Third Court of Appeals PO Box 12547 Austin, Texas 78711
"In re Eric Flores , pro se relator" 501 East 8th Street Austin Texas 78701
"In re The State of Texas , relator"
Vs.
Richard James "Rick" Perry , defendant
Trial Court Case No. D1DC14100139 Third Court of Appeals Case No. O3- \S- OOOO 3 - CK
PETITION FOR AMICUS CARIAE BRIEF IN THE PUBLIC INTEREST OF HEALTH AND SAFETY
(l)Table of Contents (2)Parties of Interest (3)Opinions Below (4)Question Presented (5)Constitutional Statutes (6)Jurisdictional Statement (7)Statement of the Case (8)Statement of Facts (9)Summary of Argument (10)Argument /RECEIVED \ (ll)Conclussion and Prayer N 11 2015 THIRD COURT OF APPEALS. Pleaded By : V JEFFREY D. KYI E / "In re Eric Flores , pro se relator" 501 East 8th Street Austin Texas 78701 (2)Parties of Interest
(i)Eric Flores is a party of interest whoms place of business is designated at 501 East 8th Street Austin Texas 78701.
(ii)Richard James "Rick" Perry is a party of interest whoms place of business is designated at Office of the Attorney General PO Box 12548 , Austin, TX 78711-2548
(iii)The State of Texas is a party of interest whoms place of business is designated at James E. Rudder Building 1019 Brazos , Austin, Texas 78701
(3) Opinion Belows
(i) Pursuant to Texas Rules of Evidence no.402 evidence relevant
to the subject matter of the case is generally admissible.
The pro se relator has filed a motion to joinder of certain offenses
that were committed by the defendant in the commission of the
pending criminal offenses in the lower district court.
Texas Rule of Evidence no.402 gives the pro se relator
jurisdictional basis to file the motion for joinder of certain offenses
that were committed by the defendant in the commission of the
pending criminal offenses in the lower district court. (4) Questions Presented
(i) Whether the Texas Rule sof Evidence no. 402 allows , enables , o rprocurrs for the pro se relator to file a motion to joinder of certain offenses that the defendant committed in the commission of the pending criminal offenses in the lower district court.
(ii) Whether the defendant is a threat to the public interest of health and safety.
(iii) Whether the pro se relator , his relatives , the prosecuteing attorney , and district judge will suffer irreparable injury such as death if the appellate court does not grant the rehef that is being seeked herein.
(iv) Whether the irreparable injury such as death that the pro se relator , his relatives , the prosecuteing attorney , the district judges , and other members of the public will suffer far outweighs the legal injury if any that the defendant will suffer if the appellate court grants the relief settforth herein.
(v) Whether the relief that is being seeked herein is in the public interest of health and safety.
(5) Jurisdictional Statement
Pursuant to Texas Rules of Appellate Procedure no. 11 an
appellate court may receive but not file an aminus cariae brief.
But the court for good cause may refuse to consider the brief and
order that it be returned. The pro se relators establishes good cause to file this foregoing
"Aminus Cariae" brief because it is of imperative importance to
the public interest of health and safety since the Aminus Cariae
brief is seeking relief from imminent danger such as death on
behalf of the public.
This means that a large number of the population will die if the
appellate court does not give consideration to the merit of this
brief.
The defendant has previously shown to be violent and hostile
when other officials are providing witness testimony to seek
criminal prosecution against the defendant, by randomly causeing
the death of members of the public until the defendants anger
subsides.
This means that it is necessary for the appellate court to consider
the merits of this brief.
The pro se relator hereby gives judicial notice that this case arises
from the commission of a crime that was committed by the
defendant against the pro se relator whom then seeked for the
Travis County District Attorneys Office Public Integerty Unit to investigate and prosecute the defendant for committing a crime
against the pro se relator and his immediate relatives.
The defendant then malinger and construed circumstance to
where the defendant could use his public office to remove the
functions of the Travis County District Attorney Public Integerty
Unit to prevent the pro se relator from launching an investigation
that could have resulted in criminal lawful sanctions against the
defendant.
After the Travis County District Attorney Public Integerty Unit
indicted Richard James "Rick" Perry for coercion of public official
to obstruct justice and abuse of power , the defendant then
threatened to cause the death of the pro se relator , his relatives ,
the prosecuteing attorney , and the district judge.
The defendant has previously carried out a death threat by
causeing the death of more than three of the pro se relators
relatives constituteing mas smurder in the first degree.
For this reason the defendant has the substantial likelihood of
carrying out his recent death threat to cause the death of the pro
se relator , his relatives , prosecuteing attorney , and the district judge assigned to the case if the appellate court does not intervene
to enforce the performance of a duty as clearly defined by law.
The irreparable injury such as death that the pro se relator , his
relatives , the prosecuteing attorney , and the district judge will
suffer far outweighgs the legal injury if any that the defendant
will endure of the appellate court does grant the relief that is
being seeked.
Although the pro se relator Eric Flores has entitled his petition
Amicus Cariae Brief however pro se relator Eric Flores petition
sounds in mandamus relief.
For this reason the pro se relator Eric Flores cites the legal basis
that invokes the appellate courts jurisdiction to enforce the
performance of a duty as clearly defined by law as settforth below
, in particular;
The Texas Constitution grants the Third Court of Appeals such
original jurisdiction as may be provided by law to enforce the
performance of a duty as clearly defined by law in the lower court
of appeals and the district courts. [Tex.Const.Art.5 ,&6].The Third
Court of Appeals has the power to issue a writ of mandamus to enforce its jurisdiction over the lower court of appeals and the
lower district court to ensure the effective and expeditious
administration of the business of the lower court of appeals and
the district court[Tex.Gov. Code & 22.221 (a). In addition , the
Third Court of Appeals has general mandamus authority against
district and county court judges that have been elected within the
jurisdictional bounderies of the State of Texas. Against these
judges , the Third Court of Appeals has the authority to issue all
writs of mandamus that are agreeable to the principles of law that
regulate the lower court of appeals and the lower district
court[Tex.Gov.Code. &22.221(b)].This provision has been
interpreted to expand the mandamus power of the Third Court of
Appeals so that it is virtuely identical to that of the lower court of
appeals[see Dickens v. Ct. of App., 2nd Sup.Jud.Dist., 727 S.W.2d
542 , 548 (Tex.Crim.App. 1987].
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&
Third Court of Appeals PO Box 12547 Austin, Texas 78711
"In re Eric Flores , pro se relator" 501 East 8th Street Austin Texas 78701
"In re The State of Texas , relator"
Vs.
Richard James "Rick" Perry , defendant
Trial Court Case No. D1DC14100139 Third Court of Appeals Case No. O3- \S- OOOO 3 - CK
PETITION FOR AMICUS CARIAE BRIEF IN THE PUBLIC INTEREST OF HEALTH AND SAFETY
(l)Table of Contents (2)Parties of Interest (3)Opinions Below (4)Question Presented (5)Constitutional Statutes (6)Jurisdictional Statement (7)Statement of the Case (8)Statement of Facts (9)Summary of Argument (10)Argument /RECEIVED \ (ll)Conclussion and Prayer N 11 2015 THIRD COURT OF APPEALS. Pleaded By : V JEFFREY D. KYI E / "In re Eric Flores , pro se relator" 501 East 8th Street Austin Texas 78701 (2)Parties of Interest
(i)Eric Flores is a party of interest whoms place of business is designated at 501 East 8th Street Austin Texas 78701.
(ii)Richard James "Rick" Perry is a party of interest whoms place of business is designated at Office of the Attorney General PO Box 12548 , Austin, TX 78711-2548
(iii)The State of Texas is a party of interest whoms place of business is designated at James E. Rudder Building 1019 Brazos , Austin, Texas 78701
(3) Opinion Belows
(i) Pursuant to Texas Rules of Evidence no.402 evidence relevant
to the subject matter of the case is generally admissible.
The pro se relator has filed a motion to joinder of certain offenses
that were committed by the defendant in the commission of the
pending criminal offenses in the lower district court.
Texas Rule of Evidence no.402 gives the pro se relator
jurisdictional basis to file the motion for joinder of certain offenses
that were committed by the defendant in the commission of the
pending criminal offenses in the lower district court. (4) Questions Presented
(i) Whether the Texas Rule sof Evidence no. 402 allows , enables , o rprocurrs for the pro se relator to file a motion to joinder of certain offenses that the defendant committed in the commission of the pending criminal offenses in the lower district court.
(ii) Whether the defendant is a threat to the public interest of health and safety.
(iii) Whether the pro se relator , his relatives , the prosecuteing attorney , and district judge will suffer irreparable injury such as death if the appellate court does not grant the rehef that is being seeked herein.
(iv) Whether the irreparable injury such as death that the pro se relator , his relatives , the prosecuteing attorney , the district judges , and other members of the public will suffer far outweighs the legal injury if any that the defendant will suffer if the appellate court grants the relief settforth herein.
(v) Whether the relief that is being seeked herein is in the public interest of health and safety.
(5) Jurisdictional Statement
Pursuant to Texas Rules of Appellate Procedure no. 11 an
appellate court may receive but not file an aminus cariae brief.
But the court for good cause may refuse to consider the brief and
order that it be returned. The pro se relators establishes good cause to file this foregoing
"Aminus Cariae" brief because it is of imperative importance to
the public interest of health and safety since the Aminus Cariae
brief is seeking relief from imminent danger such as death on
behalf of the public.
This means that a large number of the population will die if the
appellate court does not give consideration to the merit of this
brief.
The defendant has previously shown to be violent and hostile
when other officials are providing witness testimony to seek
criminal prosecution against the defendant, by randomly causeing
the death of members of the public until the defendants anger
subsides.
This means that it is necessary for the appellate court to consider
the merits of this brief.
The pro se relator hereby gives judicial notice that this case arises
from the commission of a crime that was committed by the
defendant against the pro se relator whom then seeked for the
Travis County District Attorneys Office Public Integerty Unit to investigate and prosecute the defendant for committing a crime
against the pro se relator and his immediate relatives.
The defendant then malinger and construed circumstance to
where the defendant could use his public office to remove the
functions of the Travis County District Attorney Public Integerty
Unit to prevent the pro se relator from launching an investigation
that could have resulted in criminal lawful sanctions against the
defendant.
After the Travis County District Attorney Public Integerty Unit
indicted Richard James "Rick" Perry for coercion of public official
to obstruct justice and abuse of power , the defendant then
threatened to cause the death of the pro se relator , his relatives ,
the prosecuteing attorney , and the district judge.
The defendant has previously carried out a death threat by
causeing the death of more than three of the pro se relators
relatives constituteing mas smurder in the first degree.
For this reason the defendant has the substantial likelihood of
carrying out his recent death threat to cause the death of the pro
se relator , his relatives , prosecuteing attorney , and the district judge assigned to the case if the appellate court does not intervene
to enforce the performance of a duty as clearly defined by law.
The irreparable injury such as death that the pro se relator , his
relatives , the prosecuteing attorney , and the district judge will
suffer far outweighgs the legal injury if any that the defendant
will endure of the appellate court does grant the relief that is
being seeked.
Although the pro se relator Eric Flores has entitled his petition
Amicus Cariae Brief however pro se relator Eric Flores petition
sounds in mandamus relief.
For this reason the pro se relator Eric Flores cites the legal basis
that invokes the appellate courts jurisdiction to enforce the
performance of a duty as clearly defined by law as settforth below
, in particular;
The Texas Constitution grants the Third Court of Appeals such
original jurisdiction as may be provided by law to enforce the
performance of a duty as clearly defined by law in the lower court
of appeals and the district courts. [Tex.Const.Art.5 ,&6].The Third
Court of Appeals has the power to issue a writ of mandamus to enforce its jurisdiction over the lower court of appeals and the
lower district court to ensure the effective and expeditious
administration of the business of the lower court of appeals and
the district court[Tex.Gov. Code & 22.221 (a). In addition , the
Third Court of Appeals has general mandamus authority against
district and county court judges that have been elected within the
jurisdictional bounderies of the State of Texas. Against these
judges , the Third Court of Appeals has the authority to issue all
writs of mandamus that are agreeable to the principles of law that
regulate the lower court of appeals and the lower district
court[Tex.Gov.Code. &22.221(b)].This provision has been
interpreted to expand the mandamus power of the Third Court of
Appeals so that it is virtuely identical to that of the lower court of
appeals[see Dickens v. Ct. of App., 2nd Sup.Jud.Dist., 727 S.W.2d
542 , 548 (Tex.Crim.App. 1987].
Pursuant to all subsections of Texas Rules of Appellate Procedures
no.52 (for original proceedings) the relator submits this foregoing
"Petition Sounding in Mandamus Relief' to invoke the jurisdiction
the Third Court of Appeals because it is necessary to " correct a clear abuse of discretion or the violation of a duty imposed by law
when the lower court of appeals and the district court has given
the relator no other adequate remedy at law"[CSR Ltd. V. Link,
925 S.W.2d 591 , 596 (Tex.l996)( quoting Johnson v. Fourth Court
of Appeals , 700 S.W.2d 916 , 917 (Tex.1985); see also RepubHcan
Party of Texas v. Dietz , 940 S.W.2d 86, 88 (Tex.1997).
(6) Comnstitutional Statutes
Dickens v. Ct. of App., 2nd Sup.Jud.Dist., 727 S.W.2d 542 , 548 (Tex.Crim.App. 1987].
"CSR Ltd. V. Link, 925 S.W.2d 591 , 596 (Tex.l996)( quoting
Johnson v. Fourth Court of Appeals , 700 S.W.2d 916 , 917
(Tex.1985); see also RepubHcan Party of Texas v. Dietz , 940
S.W.2d 86, 88 (Tex.1997).
Texas Rules of Appellate Procedure no. 11
Texas Constitution Article 5 & 6
Texas Government Code & 22.221(a)
Texas Government Code & 22.221(b)
Texas Rules of Appellate Procedure no.52
Texas Rules of Evdience no. 406
Texas Rule of Evidence no.405 Texas Rules of Evidence no.404
Texas Rule of Evdience no.608
Texas Rule of Evidence no.609
(7)Statement of the Case
The circumstances of this case begin when the pro se relator first
wittnessed a corrupt police officer named Paul McDowell
employed by the El Paso PoHce Department Pebble Hills Regional
Command Center in El Paso Texas to include the corrupt poHce
officers immediate relative whom were purchaseing cocaine at the
place of the petitioners mother Cynthia Lorenza Flores place of
residence.
The defendant Richard James "Rick" Perry then misused his
official capacity to influence , instruct, direct, coerce , or
otherwise bribe and osolicitate the corrupt poHce officers named
Paul McDoweU and his police coworkers then begin to use deadly
technology to cause the petitioner and his immediate relatives
severe mental or physical pain for long durations exceeding
calendar days in which was equivalent in intensity to organ failure or impairment of body functions resulting in the death of
more than four of the pro se relator immediate relatives
constitutieng mass murder in the first degree in which was solely
conspired to intimidate the petitioner and his immediate relatives
such as his mother to not reveal any information regarding the
poHce officers purchaseing cocaine at the place of the petitioners'
mothers' residency..
The petitioner then went to the El Paso PoHce Department
Internal Affairs Division to complain that a corrupt poHce officer
named Paul McDoweU and his immediate relative were
purchaseing cocaine from the petitioners mother at the place of
her residence.
The petitioner further compHaned to the El Paso PoHce
Department Internal Affairs Divisions, that the corrupt poHce
officer named Paul McDoweU and his corrupt police supervisor by
the last name of Seargent Larra from the El Paso PoHce
Department Pebble HUls Regional Command Center were using
deadly technology to cause the petitioner and his immediate
relatives severe mental or physical pain for long durations exceeding calendar days in which was equivalent in intensity to
organ failure or impairmnent of body functions resulting in the
death of more than four of the petitioners relatives.
The defendant Richard James "Rick" Perry then further misused
his official capacity to instruct, influence , direct, coerce , or
otherwise bribe and soHcitate the corrupt police officer named
Paul McDoweU and his supervisor by the last name of Seargent
Lara employed by the El Paso Police Department Pebble HUls
Regional Command Center to use advanced technology with a
direct signal to the satelite in outerspace that has the capabiHty of
calculateing a genetic code to virtually communicate statements of
intimidation such as the phrase "I'll Have You" so as to give the
indication that the corrupt poHce supervisor last name Larra"
would cause the death of the pro se relator and his immediate
relative as a retaliatory adversed act against the pro se relator for
compHaning against the corrupt poHce officer named Paul
McDoweU to the El Paso PoHce Department Internal Affairs
Division. Thereafter the petitioner then went to the El Paso Police
Department Internal Affairs Division a second time to compHan
that corrupt poHce officer named Seargent Larra was threatening
to cause the death of the pro se relator or his immediate relatives
as a retaHatory adversed act against the pro se relator for
complaining to the El Paso PoHce Department Internal Affairs
Divisions.
Four months later the defendant Richard James "Rick" Perry
further misused his official capacity to influence , instruct, direct
,coerce , or otherwise bribe and soHcitate the corrupt police officer
named Paul McDowell to carry out the death threat by shooting
and killing the pro se relators' brother Javier Flores Junior and
then implanting evidence into the shooting crime scene such as a
knife so as to be able to falsely alleged that the scratch wounds
that the corrupt poHce officer named Paul McDoweU had on his
face that were inflicted by his female immediate relative in
another incident that had occurred prior to the shooting incident
in anticipation to be able to allege that the scratch marks were the
knife wounds that the pro se relators brother Javier Flores Junior inflicted on the corrupt police officers face with the knife that the
poHce officer implanted into the shooting crime scene so as to
falsely justify the corrupt poHce officers actions of using a weapon
such as a gun to shoot and kiU the pro se relators' brother Javier
Flores Junior in which was solely conspired to cover up any
premeditative motive that the pro se relator had estabHshed by
reporting the poHce officers death threats to the El Paso PoHce
Department Internal Affairs Divisions four months before the
corrupt poHce officer named Paul McDoweU had actually carried
out the death threat by shooting and killing the pro se relators
brother Javier Flores Junior.
The defendant Richard James "Rick" Perry further misused his
official capacity to impanel specific members of a state grand jury
with the view of secureing a not guUty verdict against the police
officer named Paul McDowell for shooting and killing the pro se
relators brother Javier Flores Junior by intentionally and
knowingly withholding evidence from the grand jury knowledge
such as pro se relators compHant to the El Paso Police
Department Internal Affairs Divisions against poHce officer Paul McDoweU and supervisor last name (Larra) death threat which
was made four months before poHce officers carried out death
threat by shooting and kilHng the pro se relators brother Javier
Flores Junior.
The corrupt poHce officer named Paul McDoweU and his corrupt
coworkers Seargent Larra further conspired to UlegaUy
incarcerate the pro se relator before shooting and kilHng the
petitioners brother Javier Flores Junior so that the pro se relator
could not be able to tell the investigative detectives at the time of
that the shooting incident occurred , that the pro se relator had
complained to the El Paso Police Department Internal Affairs
Division that the corrupt police officer named Paul McDoweU and
his corrupt supervisor named Larra had threatened to ldll the pro
se relator or his immediate relatives which was reported to the El
Paso PoHce Department Internal Affairs Divisions four months
before the corrupt poHce officer named Paul McDoweU actuaUy
carried out the death threat by shooting and killing the pro se
relators brother Javier Flores Junior so as to coincide with the corrupt police officers Paul McDowell conspiracy to cover up
premeditated capital murder in the first degree.
official capacity to influence , instruct, direct, coerce , or
otherwise bribe and solciitate the corrupt poHce officers named
Paul McDoweU and his corrupt supervisor named Larra to further
conspired to send their immediate relatives to take turns sexuaUy
assualting the pro se relators mother Cynthia Lorenza Flores and
hold her hostage at the place of her residence so as to prevent her
from communicateing to state or federal law enforcement agencies
to compHan that she was being sexuaUy assualted by the same
poHce officers that conspired to kiU her son Javier Flores Junior.
The corrupt police officer named Paul McDowell and his corrupt
supervisor named Larra first sent a person of mexican american
national origin by the first name of Eddie Shaal that was directly
related to another corrupt law enforcement poHce officer, whom
repeatedly sexuaUy assaulted the petitioners mother Cynthia
Lorenza Flores and held her hostage at the place of her residence
so as to prevent her from complaining to state or federal law enforcement agency that she was being sexually assaulted by the
same police officers that conspired to kUl her eldest son Javier
After the pro se relator was released from iUegally incarceration
the pro se relator caUed the 911 emergency hotline system to
compHan that several police officers were sending different
persons portraying to have the same named Eddie Shaal to
sexuaUy assualting the mother (Cynthia Lorenza Flores) of the
person (Javier Flores Junior) that the corrupt poHce officers
murder.
The poHce department declined to prosecute the sexual assualt
incident because poHce officers were involved in sending
immediate relatives to sexuaUy assualt the mother (Cynthia
Lorenza Flores) of the person (Javier Flores Junior) that the
corrupt poHce officers murder.
official capacity to influence , direct, coerce , intimidate , or
otherwise bribe and soHcitate the corrupt poHce officers named
Paul McDowell and his corrupt supervisor named Larra to retahate against the pro se relator for calling 911 emergency
hotline to complain against the police officers that were sexually
assaulting the pro se relator mother Cynthia Lorenza Flores by
using advanced technology with a direct signal to the sateHte in
outerspace that has the capabUity of calculateing a genetic code to
cause the petitioners mother Cynthia Lorenza Flores severe gul
blatter pain for long durations exceeding calendar days in which
was equivalent in intensity to impair her gul blatter functions
almost leading to her death requireing medical treatment from a
forensic medical professional in a freeworld hospital to keep her
from dieing in which was solely conspired to intimidate the pro se
relators mother to not only be prohibited from going to state or
federal law enforcement agencies to report that she was being
sexuaUy assualted by the immediate relatives of the same corrupt
poHce officers that first conspired to kiU her son Javier Flores
Junior , but also the corrupt poHce officers actions of using deadly
technology to torture the pro se relators mother was to intimdate
the pro se relators mother to go to the poHce department to state
that she was not being sexuaUy assualted so as to be able to charge the pro se relators with the criminal offense of false
reporting to iUegally incarcerate the pro se relator for the purpose
of preventing the pro se relator from continue to communicateing
to state or federal law enforcement agencies with the specific
intent of preventing a judicial investigation that can result in
criminal lawful sanctions against the defendant, his co
conspiratoring corrupt police officers and their immediate
relatives for takeing turns repeatedly sexuaUy assualting the
mother (Cynthia Lorenza Flores) of the person (Javier Flores
Junior) that the corrupt poHce officers conspired to murder.
The pro se relators mother had just gotten out of the hospital as a
result of being tortured almost leading to her death and feared for
her life to the extent that she felt so intimidated that she compHed
with the defendant and his co conspiratoring corrupt poHce
officers demands to go to the police department to state that she
was not being sexually assualted so as to prevent a criminal
investigation that can result in criminal lawful sanctions against
the defendant and his co conspiratoring corrupt poHce officers and their immediate relatives for takeing turns repeatedly sexaully
assaulting the petitioners mother (Cynthia Lorenza Flores).
The defendant Richard James "Rick" Perry then further misusued
his official capacity to influence , direct, coerce , instruct, or
otherwise bribe and soHcitate the corrupt police officers to
instructed the first person of mexican american national origin by
the first name of Eddie Shaal to leave the pro se relator mothers
place of residence to avoid criminal charges only to be replaced by
another corrupt law enforcement official such as a heavy sett,
bald head , mexican sheriff deputy employed by the El Paso
County Sheriff Department in El Paso Texas that was also
portraying to be named Eddie Shaal whom was assigned to the El
Paso County Court House located at 500 East San Antonio Avenue
El Paso Texas 79901.
The corrupt sheriff deputy repeatedly sexually assualted the pro
se relator mother Cynthia Lorenza Flores and held her hostage by
accompanieing her to her work place and back to her place of
residence on a daily basis so as to make sure that she would not go
to state or federal law enforcement agency to complain that she was being sexually assaulted by the immediate relatives of the
same corrupt police officers that murder her son Javier Flores
Junior.
Thereafter the pro se relator then went to the El Paso County
Sheriff Department Internal Affairs Division to compHan against
the sheriff deputy that was sexuaUy assualting the pro se relator
mother Cynthia Lorenza Flores.
As a result the defendant Richard James "Rick" Perry further
misused his official capacity to influence , instrict, direct, coerce ,
or otherwise bribe and soHcitate the corrupt police officer named
Paul McDowell to instruct the sheriff deputy leave the pro se
relators mother place of residence to avoid criminal charges only
to be replaced by a third person of mexican american national
origin that was also portraying to be named Eddie Shaal however
the third person was actually a campus police officer from the El
Paso Community CoUege VUla Verde Campus located at 919
Hunter Dr., El Paso Texas 79927.
The corrupt campus poHce officer that was a person of mexican
american national origin whom was also portraying to be named Eddie Shaal also repeatedly sexaully assaulted the pro se relator
mother and held her hostage at the place of her residence to
prevent her from communicateing to state or federal law
enforcement agencies to compHan that she was being sexually
assualted by the same corrupt police officers that conspired to kUl
her son Javier Flores Junior.
By then the pro se relator had already started complaining to the
El Paso County District Attorney Jaime Ezparza in El Paso Texas,
that several corrupt police officers were sending their friends ,
coworkers , or relatives to sexauUy assaulting the mother (Cynthia
Lorenza Flores) of the person (Javier Flores Junior) that the
corrupt poHce officers conspired to murder.
The corrupt campus police officer that was portaying to be named
Eddie Shaal retaliated against the pro se relator for complaining
to the El Paso County District Attorney Jaime Ezparza by using
advanced technology with a direct signal to the satelite in
outerspace that has the capability of calculateing a genetic code to
cause the petitioners' mother Cynthia Lorenza Flores severe heart
pain for long durations exceeding calendar days in which was equivalent in intensity to cardiac and respatory faUure almost
leading to her death requireing medical treatment from a forensic
medical professional in a freeworld hospital to keep her from
dieing in which was solely conspired to intimidate the pro se
relators' mother to beHeve that the corrupt police officers would
use deadly technology to torture her to death in order to make the
pro se relators mother comply with the corrupt police officers
demands to divorce her husband and remarry one of the person
that was takeing turns sexually assaulting her for the purpose of
influenceing the justice officials to beHeve that because the pro se
relators' mother married one of the corrupt poHce officers or their
immediate relatives that were takeing turns sexauUy assaulting
the pro se relators mother therefore the pro se relators mother
was not being sexaully assualted so as to prevent a criminal
investigation that can result in criminal lawful sanctions against
the defendant and his co conspiratoring corrupt poHce officers or
their immediate relatives for sexauUy assaulted the mother
(Cynthia Lorenza Flores) of the person (Javier Flores Junior) that
the corrupt police officers conspired to murder. The corrupt campus police officer then left the pro se relators'
mothers' place of residence to avoid criminal charges , only to be
replaced by a fourth person of mexican american national origin
that was also portraying to be named Eddie Shaw whom was
directly related to the detective named Julio Ordaz from the El
Paso PoHce Department Internal Affairs Division whom first
interviewed the pro se relator at the time that the pro se relator
went to the El Paso Police Department Internal Affairs Division to
compHan against the corrupt police officers Seargent Larra
making threats to cause the death of the pro se relator or his
immediate relatives in which was four months before the corrupt
poHce officer named Seargent Larras and his corrupt poHce
coworker named Paul McDowell carried out the death threat by
shooting and kilHng the pro se relators brother Javier Flores
It seemed as if the poHce detective named Julio Ordaz from the
internal affairs division decided to cover up the fact that the pro se
relator had reported the corrupt poHce officers Seargent Larras'
death threats to the internal affairs division detective named JuHo Ordaz four months before the corrupt police officer named Paul
McDoweU had actually carried out the death threat by shooting
and kilHng the pro se relators' brother Javier Flores Junior in
which was so that the corrupt detective named Julio Ordaz could
participate in sending his immediate relative to sexually assualt
the pro se relators mother Cynthia Lorenza Flores.
official capacity to influence , instruct, coerce , direct, or
otherwise bribe and soHcitate another corrupt detective named
JuHo Ordaz to conspire to bribe or soHcitate an attorney at law
named Victor Parra to coerce , intimidate , force , or otherwise
make death threats against the pro se relators mother to
intimidate her to pay for the services of the attorney at law named
Victor Parra for the purpose of forceing the pro se relator mother
into divorceing her husband with the specific intent of remarrying
one of the four person that was takeing turns sexually assualting
the pro se relators mother so as to be able to influence the justice
officials to beHeve that because the pro se relators mother Cynthia
Lorenza Flores remarried one of the persons that was takeing turns sexually assualting her therefore she was not being sexuaUy
assualted to prevent a criminal investigation that can result in
criminal lawful sanctions against the defendant and his co-
conspiratoring corrupt police officers or their immediate relatives
for sexaully assualting the mother (Cynthia Lorenza Flores) of the
person (Javier Flores Junior) that the corrupt police officers
conspired to murder.
The divorce dispute was filed in the El Paso County 383rd Judicial
District Court located at 500 East San Antonio Avenue El Paso
Texas 79901 presideing family district judge Mike Herrera whom
was also notified of the aforementioned circumstances but decided
to proceed with the divorce anyway.
The defendant Richard James "Rick" Perry had substantive
knowledge that the pro se relator would seek for the Travis
County District Attorney Office PubHc integerty Unit to conduct
an investigation into the murder into the relators brother Javier
Flores Junior and the sexuall assault of the relators mother which
could have resulted in criminal lawful sanctions against the
defendant for misuseing his official capacity to instruct corrupt poHce officers and their coworkers or relatives to take turns
sexuaUy assaulting the pro se relators mother Cynthia Lorenza
Flores.
Therefore the defendant malingered and construed circumstances
to where he could obstruct justice to prevent the Travis County
District Attorney Public Integerty Unit from launching an
investigation in the murder of the pro se relators brother Javier
Flores Junior and sexual assault of relators mother Cynthia
Lorenza Flores.
Whereby the defendant Richard James "Rick" Perry misused his
official capacity to influence , instruct, direct, coerce , or
otherwise bribe and soHcitate another poHce relative sit and wait
for a particular day when the Travis County District Attorney
Rosemary Lemhberg would drink on special occasions such as
birthday parties , get together , annerversiaries , Christmas , and
New Year in which was so that the poHce relative could arrest the
Travis County District Attorney Rosemary Lehmberg for drunk
driving and thereby maliner and construe circumstances to
promote a sufficient reason to not only remove the district attorney from her official capacity to appoint another person to
preside as district attorney whom would ensure that no criminal
investigation would be launched into the murder of the relators
brother and the sexual assault of the relators mother but also to
Create a good reason to veto funding to the Travis County District
Attorney Public Integerty Unit for the purpose of eliminateing any
pubHc office with the jurisidictional abiHty to launch investigation
into aUegation against high profile elected official such as the
defendant with the specific intent of prevent a judicial
investigation that could have resulted in criminal lawful sanctions
against the defendant and his co-conspiratoring corrupt police
officers for murder the relators brother Javier Flores Junior and
sexuaUy assaulting the relators mother Cynthia Lorenza Flores.
Based on these circumstances the pro se relator submitted several
compHants requesting that the the Travis County District
Attorney Rosemary Lehmberg to enforce the law by criminally
prosecuteing the corrupt police officers and their immediate
relatives whom were takeing turns sexuaUy assualting the mother (Cynthia Lorenza Flores) of the person (Javier Flores Junior) that
the corrupt police officers had murdered.
However Travis County District Attorney Rosemary Lehmberg
refused to enforce the law by not criminaUy prosecuteing the
corrupt poHce officers or their immediate relatives for takeing
turns sexually assualting the petitioners' mother (Cynthia
Lorenza Flores) in which was because the defendant had veto
funding to the Travis County District Attorney Public Integerty
Unit for the purpose of eliminateing any public office with the
jurisidictional abiHty to launch investigation into aUegation
against high profile elected official such as the defendant with the
specific intent of prevent a judicial investigation that could have
resulted in criminal lawful sanctions against the defendant and
his co-conspiratoring corrupt poHce officers for murder the relators
brother Javier Flores Junior and sexually assaulting the relators
mother Cynthia Lorenza Flores. These circumstances clearly show that the defendant is
obstructing justice by engageing in standard of conduct that
allows , enables , or procurrs for corrupt poHce officers and their
immediate relatives to force a victum named Cynthia Lorenza
Flores that has been sexuaUy assaulted by the corrupt police
officers or their immediate relatives, to pay for the legal services
of an attorney named Victor Parra for the purpose of initiateing a
cause of action to divorce her husband with the specific intent of
enableing the attorney at law named Victor Parra to force the
victum named (Cynthia Lorenza Flores) to remarry one of the
corrupt poHce officers or their immediate relatives that was
repeatedly sexuaUy assaulting the victum named Cynthia Lorenza
Flores and holding the victum named Cynthia Lorenza Flores
hostage at the place of the victums named Cynthia Lorenza Flores
residence so as to influence justice officials to believe that the
victum named (Cynthia Lorenza Flores) is not being sexuaUy
assaulted because the victum named (Cynthia Lorenza Flores) has
been forced to remarry one of the corrupt police officer or their immediate relatives that was sexually assaulting the victum
named Cynthia Lorenza Flores as a form of obstruction of justice.
In the present circumstances of the case , the Travis County
District Attorney Rosemary Lehmberg has indicted the defendant
Richard James "Rick" Perry for coercion of a public official and
abuse of power.
The pro se relator has filed a motion to joinder of certain offenses
that the defendant committed in the commission of the criminal
offense settforth in the states indictment.
The defendant has appealed to the Third Court of Appeals in
attempt to through out the indictment before the anyone finds out
about the circumstances of this case.
(8) Statement of Fact
Pursuant to Texas Rule of Criminal Procedure Article 21.24
(a) Two or more offenses may be joined in a single indictment,
information, or complaint, with each offense stated in a separate
count, if the offenses arise out of the same criminal episode, as
defined in Chapter 3 of the Penal Code. r
(b) A count may contain as many separate paragraphs charging
the same offense as necessary, but no paragraph may charge more
than one offense.
(c) A count is sufficient if any one of its paragraphs is sufficient.
An indictment, information, or complaint is sufficient if any one of
its counts is sufficient.
The pro se relator has filed a motion to joinder of certain offenses
that the defendant committed in the commission of the pending
criminal offenses as settforth in the States' indictment.
However the defendant may use Texas Rule of Evidence no.608 or
609 to attack the pro se relators character crediability based on
relators criminal conviction which has nothing to do with this
case.
However pursuant to Texas Rule of Criminal Procedure no. 408 if
the relator can prove that the joinder of criminal offenses was a
routine habit of the defendant, then nothing is left to decide upon
the relators crediability regardless of the relators criminal
conviction. J
On those basis the relator conduct that it is the defendant routine
habit to misuse his official capacity to influence , direct,coerce ,
instruct, or other bribe and soHcitate another police relative to sit
and wait for a particular elected official to drink on special
occasions for the purpose of conspireing to arrest the elected
official for drunk driving with the specific intent of removeing that
particular elected official from public official in the commission of
faciHtateing a conspiracy to obstruct justice such as preventing
the elected official from participateing in a criminal investigation
that can result in criminal laful snactions against the defendant
for continuesly engageing in negligent torturious conduct whUe in
pubHc office.
The relator hereby gives judicial notice of an elected official named
Naomi Gonzales whom was elected state senator in the past year
whom was also a victum to the defendants routine habit of
sending a police officer or relative to sit and ait for the elected
senator Naomi Gonzales to drink on special occasion for the
purpose of conspireing to arrest the elected official named Naomi
Gonzales with the specific intent of removeing her from pubHc office in the commission of facUitateing a conspiracy to prevent
that elected official from participateing in criminal investigation
that could have resulted in criminal lawful sanctions against the
defendant for continuesly engageing in negHgent torturious
conduct whUe in pubHc office.
The defendant has enacted this same habit or routine against the
Travis County District Attorney Rosemary Lehmberg in the
commission of facUitateing a conspiracy to obstruct justice to
prevent Rosemary Lehmberg from participateing in an
investigation that can result in criminal lawful sanctions against
the defendant for soHcitateing premeditative capital murder of
Javier Flores Junior and sending different poHce officers or
persons to sexuaUy assault the mother of the victum the
defendant conspired to murder.
Because there is evidence such as other witness testimony
regarding the defendants habit or routine therefore nothing is left
to decide upon the relators crediablity when determine the
validity of joining certain offenses committed by the defendant
against the relator and his immediate relatives. <
\
(9) Summary of Argument
(A)Standard of Review for Abuse of Discretion
A clear abuse of discretion is found only when the reviewing
courts actions were "so arbitrary and unreasonable as to amount
to a clear and prejudicial error of law.The test is whether the
reviewing court clearly "acted without reference to any guiding
rules and principles of law ," or "whether the act was arbitrary or
unreasonable". In an appeal, to determine if there is an abuse of
discretion , the reviewing court wiU review the entire record. The
Texas Supreme Court interpreted the phrase "a decision so
arbitrary and unreasonable as to amount to a clear and prejudicial
error of law ," stating that it has different appHcations in different
cases depending upon the circumstances of each case.If the relator
seeks to overrule a reviewing court decision based on factual
issues or matters committed to the reviewing court discretion ,
"the relator must show the reviewing court could have
reached only one decision under the facts of law ".A
reviewing court has no discretion to determine the law or to apply
the law to the facts incorrectly.If the relator's complaint is that 1 «
the reviewing court incorrectly decided an issue of law , the relator
must show that the reviewing agencies faUed to analyze or apply
the law correctly because a reviewing court erroneous
interpretation of the law constitutes a clear abuse of
discretion.Traditionally , a appeal is used to establish error for the
purpose of compeHng the performance of a ministrial act or duty.
An appeal may be granted to control the conduct of the reviewing
court when the duty to do the act commanded is ministrial and
nondiscretionary.An act is ministrial if the law prescribes the duty
to be performed by a reviewing court with such precision and
certainty that nothing is left to the exercise of discretion or
judgement. An act is not ministrial if it involves the exercise of
discretion or judgement in determineing whether the duty exists.
An appeal is appropriate when the reviewing court or the person
that is the object of the writ refused to perform an act required by
law.
An appeal will issue only to "correct a clear abuse of discretion or
the violation of a duty imposed by law when there is no other
adequate remedy by law". If the basis of the appeal is the performance of a legal duty , an appeal wUl not be granted unless
the appeal shows that the relator has a clear right to the
performance of the particular duty sought to be enforced.A party
must be legaUy entitled to the requested reHef.
(9)Argument
The reviewing courts actions wiU be so arbitruary and
unreasonable so as to amount to a prejudicial error of law , if the
reviewing court refuseing to aUow the relator to participate in the
prosecution of this case which can be constituteing as aiding and
abideing the defendant in the commission of a crime to obstruct
justice.
The reviewing court will act without any reference to the guideing
rule s and principles of law , if the reviewing court does not aUow
the relator to participate in the prosecution of this criminal case
which can be constituted as aiding and abideing the defendant in
the commission of a crime to obstruct justice in which is because
the reviewing court can only reach one decision under the facts of law as clearly defined by the Texas Rules of Criminal Procedure
Artilce 21.24 which is to allow the relator to joinder of certain
criminal offenses committed by the defendant in the commission
of the pending criminal offenses as settforth in the States
indictment.
This means that the reviewing court would be analyzeing or
interpreteing the facts or rule of law incorrectly by refuseing to
aUow the relator to participate in joining certain offenses that the
defendant committed in the commission of the pending criminal
offenses as settforth in the State's indictment because of the
reviewing courts errornous interpretation of the law which can be
constituted as a clear abuse of discretion.
The act that the relator seeks to compel an act under Texas Rules
of Criminal Procedure 21.24 that is ministerial because it
prescribes the duty to be performed by a reviewing court with
such precision and certainity that nothing is left to the exercise of
discretion or judgement. & ^ s
The relator has filed his motion for joinder of certain offesnes
commited by the defendant in the commission of the criminal
offenses as settforth in the State's indictment.
However the lower district court has refused to consider relator
motion for joinder of certain offenses becaue of the serious nature
of the criminal case which can be constituted as an abuse of
discretion.
The relator is entitled to rehef sought not only because the
criminal offenses settforth in the States indictment stemmed from
the commission of a crime committed by the defendant against the
relator but also because the relator has the constitutional right to
access to the court to challenge a constitutional deprivation of life ,
Hberty , and life committed by the defendant.
(11) Conclussion and Prayer
Wherefore Primises Considered in conformance with the
reprequisites settforth herein the relator prays that the reviewing
court to enforce the performance of a duty that is clearly defined
under the law by ministrially compeling the trial court to consider •9- \
the relator motion for joinder of certain offenses as defined by
Texas Rules of Criminal Procedure 21.24.
The relator further prays that the reviewing court enter a
preHminary injunction during the pendency of this appeal to
protect the relator , his immediate relatives , the district judge ,
and the prosecuteing attorney from being the victum of the
defendants intimidation , torture , coercion , death threats , and/or
serial kUling rampage.
The relator prays for general reHef as clearly defined by law.
Iric Flores , pro se relator
501 East 8th Street Austin Texas 78701
Pursuant to Penalty of Perjury (28 U.S.C. & 1746) the relator
hereby states , declares , and certifies that the foregoing brief is
true and correct. \
CERTIFICATE OF SERVICE
Pursuant to Penalty of Perjury (28 U.S.C. & 1746) the relator
hereby states, declares , and certifies that true and correct copies
of this foregoing brief was sent to the following parties of interest
settforth below , in particular ;
(i)Eric Flores is a party of interest whoms place of business is designated at 501 East 8th Street Austin Texas 78701.
(ii)Richard James "Rick" Perry is a party of interest whoms place of business is designated at Office of the Attorney General PO Box 12548 , Austin, TX 78711-2548
(in)The State of Texas is a party of interest whoms place of business is designated at James E. Rudder BuUding 1019 Brazos , Austin, Texas 78701 in PkiuKUmX * MAIL * ill
|| lg VISITUSATUSPS.COM- Labd106A. July2013 g^ UN,TED•>$(&&* m^sm^^* "~ Iff Slof^L^of^0" &.«aiat
FROM:
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TO:
EP14F July 2013 VISIT US AT USPS.COM0 UNITED 1 PS00001000014 OD: 12.5 x 9.5 ORDER FREE SUPPLIES ONLINE POSTALS
< To : Third court of Appeals P.O. Box 12547, Austin Texas 78711
From: Eric Flores, pro se relator 200 W. Mockingbird Lane Austin Texas 78745
Date: June 7, 2015
Re; Amicus Brief in the Public Interest of Health and Safety
To the Clerk of the Appellate Court, Enclosed is an amicus brief that is seeking relief from imminent danger such as death on behalf of the public in general, that is attached to a motion to proceed informa pauperis which I am requesting to be filed and submitted for review by the appellate court. The pro se relator Eric Flores is indigent and can only provide one copy of the amicus cariae brief and motion to proceed informa pauperis on appeal. Because the amicus cariae brief is seeking relief from imminent danger such as death the appellate clerk offices does not have the discretion to refuse to file the amicus cariae brief solely because it is not in compliance with the rules of the appellate court. The appellate clerk must submit the amicus cariae brief to be reviewed by the appellate panel whom shall only have the discretion to determine whether the amicus cariae brief should be returned to its sender to correct the noted deficiencies or to properly adjudicate the amicus cariae brief by the constitutional requirement of due process of law. The pro se relator request that the appellae clerk refrain from sending the amicus cariae brief back to the sender because it is seekng relief from imminent danger such as death on behalf the public in general. The pro se relator hereby gives the appellate clerk judicial notice that the defendant has already caused the death of several people and has the substantial likelihood of causeing the death of more people f f the appellate panel fails to intervene. This means that the defendant will cause the death of more people <>f the appellate panel refuses to file and consider the merits of this amicxus cariae brief. The pro se relator prays that justice prevail.
pro se relator ^RECEIVED 8401 Boeing Dr., El Paso Texas 79910 JUN 1 1 2015 THIRD COURT OF APPEALS \ JEFFREY D. KYI F Third Court of Appeals PO Box 12547 Austin, Texas 78711 Telephone: (512) 463-1733
PlaintiffiPetiriorier\ ) Civil Action No. O**>-\S~-0<76(?3-CK Defendant/Respondent
APPLICATION TO PROCEED IN THIRD COURT OF APPEALS WITHOUT PREPAYING FEESS OR COST
Affidavit in Support of the Application Instructions
I am a plaintiffor petitioner in this case and declare Complete all questions in this application and then sign it. that I am unable to pay the costs of these proceedings Do not leave any blanks: if the answer to a question is "0," and that I am entitled to the relief requested. I declare "none," or "not applicable (N/A)," write that response. If underpenalty of perjurythat the information below is you need more space to answer a question or to explain your true and understandthat a false statement mayjesult in answer, attach a separate sheet of paper identified with your a dismissal of i name, your case's docjset number, and the question number.
Signed: Date:
For both you and your spouse estimate the average amount of moneyreceivedfrom each ofthe following sources during the past 12 months. Adjustany amount that was receivedweekly, biweekly, quarterly, semiannually, or annually to showthe monthly rate. Usegrossamounts, that is, amounts before any deductions for taxes or otherwise.
Income source Average monthly income Income amount expected amount during the past 12 next month months You Spouse Employment 7T7 Self-employment $
Income from real property (such asrental income)
Interest and dividends a o Gifts o Alimony RECEIVED N Q. Child support •IHN 112015 $ Q/ kTHlRD COURT OFAPPEALS JEFFREYf Page 2 of 5
AO 239 (Rev. 01/15) Application to Proceed in District Court Without Prepaying Fees or Costs (Long Form)
Retirement (such as socialsecurity, pensions, annuities, insurance) Disability (such associal security, insurance payments) a a Gl a Unemployment payments
Public-assistance (such as welfare) a. ¥Pr Other (specify): o. 0.00 0.00 0.00 Total monthly income:
List your employment history for the past two years, most recent employer first. (Gross monthly payis before taxes or other deductions.)
Employer Address Dates of employment Gross monthly 3ntniy pay p
$
wn? 77 List your spouse's employment history for the past two years, most recent employer first. (Gross monthly pay isbefore taxes or other deductions.)
How much cash do you and your spouse have? $ Below, state any money you or your spouse have in bank accounts or in any other financial institution. Financial institution Type of account Amount you have Amount your spouse has
^ S tz £2 $ 72 $ S If youare a prisoner, you must attach a statement certified bythe appropriate institutional officer showing all receipts, expenditures, and balances duringthe last six months in your institutional accounts. If you have multiple accounts, perhaps because you have been in multiple institutions, attach one certified statement of each account. Page3 of 5
AO239 (Rev. 01/15) Application to Proceed in District Court Without Prepaying Fees orCosts (Long Form)
5. Listthe assets, and theirvalues, which you ownor your spouse owns. Do not list clothing and ordinary household furnishings. Assets owned by you or your spouse
Home (Value) $
Other real estate (Value) $ 9? dy ^S> Motor vehicle #7 (Value) $ & Make and year:
Model:
Registration #:
Motor vehicle #2 (Value) $ rv Make and year:
Other assets (Value) $ S3 Other assets (Value) $ CJ State every person, business, or organization owing you or your spouse money, and the amount owed. Person owing you or your spouse Amount owed to you Amount owed to your spouse money
72 d 71 71 37 State the persons who rely on you or your spouse for support. Name (or, if under 18, initials only) Relationship Page4 of 5
AO 239 (Rev. 01/15) Application to Proceed in District Court Without PrepayingFees or Costs (Long Form)
Estimate the average monthly expenses of you and your family. Show separately the amounts paid by your spouse. Adjust any payments that are made weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. You Your spouse
Rent or home-mortgage payment (including lot rented for mobile home) Are real estate taxes included? D Yes iJ^No Is property insurance included? O Yes T^CNo c^ t O Utilities (electricity, heatingfuel, -water, sewer, andtelephone) T2_ $
Home maintenance (repairs andupkeep) £Z Z31 Food £3 zz Clothing *=£. Laundry and dry-cleaning Z2 Medical and dental expenses £^2 22 Transportation (not including motor vehicle payments)
Recreation, entertainment, newspapers, magazines, etc.
Insurance (notdeductedfrom wages or included in mortgage payments)
Homeowner's or renter's:
Life:
Health:
Motor vehicle:
Other:
Taxes (not deductedfrom wagesor included in mortgage payments) (specify):
Installment payments ^T Motor vehicle: c^ Credit card (name):
Department store (name):
Alimony, maintenance, and support paid to others cz^ Page 5 of 5
AO 239 (Rev. 01/15) Application to Proceed in District Court Without Prepaying Fees or Costs (Long Form)
Regular expenses for operation of business, profession, or farm (attach detailed statement) $ fy * -*r)
Other (specify): $ CJ^ •$ ^^/O.OO <-£ Total monthly expenses: >£^y o.oo
Do you expect any major changes to your monthly incomeor expenses or in your assets or liabilitiesduring the next 12 months?
a Yes ^No If yes, describe on an attached sheet.
10. Have you spent — odwill you be spending — any money for expenses or attorney fees in conjunction with this lawsuit? O Yes &£no If yes, how much? $
11. Provide any other information that will help explain why you cannot pay the costs of these proceedings.
12. Identify the city and state of your legal residence..
Your daytime phone number: ^\2 SJl^P / ^<3 ' Your age: QH Your years ofschooling: *-f u^
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