Jackson, Andrew Lee

• Court: Court of Appeals of Texas
• Decided: September 1, 2015
• Docket: WR-3,576-15
• Status: Published

Opinion

ANDREW LEE JACKSON #621203 Coffield Unit 2661 FM 2054 Tennessee Colony, TX 75884 AUgUSt 24, 2015

Clerk Court of Criminal Appeals SUpreme Court Building 201 w. 14th Street - Rrn 106 RECEIVED IN COURT OF C~MINALAPPEALS Austin, Texas 78701 SEP 0 ·1 2015 RE: ANDREW LEE JACKSON VS. CARTER THOMPSON, Respondent WRIT OF MANDAMUS ~Atosm, Oterk

Dear Clerk: Please find enclosed the original copy of my Writ of Mandamus to be filed with The Court of Criminal Appeals. Thank you for your assistance in this matter.

ALJ/ Encls. cc: File IN THE .. COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS

§ ANDREW LEE JACKSON, § Relator, Pro Se § § § vs. § CAUSE NO'S F-91-04916-IL & § F-92-02256-IL § CARTER THOMPSON, § CRIMINAL DISTRICT JUDGE, § .,.;..: CRIMINAL DISTRICT COURT NO. ~ § DALLAS COUNTY, 'TEXAS §

Respondent

PETITION FOR WRIT OF MANDAMUS

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

Comes now Andrew Lee Jackson, relator, and files this application

for Writ of Mandamus directing Carter Thompson, respondent, to Rule on

Applicant's Motion For An Order Appointing An Expert Handwriting Document

Examiner in the above Cause Numbers. In support of this application,

relator shows the Court the following:!

I.

On: March 30, 2015, relator filed an Motion For An Order Appointing An

Expert Handwriting Document Examiner to examine and attest to findings of deliberate forgery of the original Arrest Warrants in the CaH§e Numbers

by the Affiant, Richard Bender, a Police Detective of Grand Prairie, Texas,

who knowingly forged said instruments, which said discovery recently made

of this flagrant outrageous police misconduct established in Applicant's.-

-1- Motion along with factual (recent) Exhibits in order to comfirm said

forgery by An Handwriting Document Examiner in order to present further

proceedings of this newly discovered evidence extablished by an handwrit-

ing document examiner with Habeas Corpus proceedings to this Honorabi~

Court without any further impediment of Court No. ~ of Dallas County in

pursuant to Article 11.07 §3(d), 26.04, 26.05, 1.051(d)(3), 1149, and

the opening clause of 28 u.s.c.A. 2254 (e)(2), as stated in Applicant's

Motion For An Order Appointing An Expert Handwriting Document Examiner-

filed on: March 30, 2015 in Court No. 5.

II. Relator would sho~ this Honorable Court that he has on (2) occassions

inquired of the Dallas County Court No. ~ of the status of the above

stated Motion without ever receiving any type of response. SEE~ Exhiibts

~-1 & 1, attached herewith. SUPPORTING ARGUMENT:

III. The relator has no adequate remedy of law to pursue the requested

relief other than this application. IV.

This Court has jurisdiction to issu~ a Writ of Mandamus in this Cause under Article 5, Section 5 of the Texas Constitution and Article 4.04 of the Code of Criminal Procedure.

WHEREFORE, relator prays the Court grant this Application and issue . I a Writ of Mandamus directing Carter Thompson, !criminal District court_

2- ' .. '' I I I No. ~of Dallas County, Texas, Respondent to Rule on Applicant's Motion I

For An Order Appointing An Expert Handwriting iDocument Examiner in Cause . I Numbers F-91-04916-IL & F-92-02256-IL, filed with that court on: March I 30, 2015, and any other relief this Honorable !court may deem neccessary I

SE

Andrew Lee Jackson #621203 Coffield Unit 2661 FM 2054 Tennessee Colony, TX 75884

DECLARATION I, Andrew Lee Jackson, TDCJ-ID N0.621203, presently incarcerated in the Texas Department of Criminal Justice-Institutional Division verify and declare under penaly of perjury the foregoing statements are true and correct.

on•;&rv-,:i ~""/_ , Executed 2015 /sl~_/~--r-r---~ ANDREW LEE JAC PRO SE

CERTIFICATE OF SERVICE I vertfy that a true and correct copy of this instrument was mailed to the Respondent by way of Jhe Da~las District Clerk's Office by 1st class u.s. Mail on thi~;/~ day of August, 2015.

Page Three/Final EXHIBIT~

ANDREW LEE JACKSON #621203 Coffield Unit 2661 FM 2054 Tennessee Colony, TX 75884 April 27, 2015

Victoria Franklin Official Court Reporter Criminal District Court No. ~ 133 N. Riverfront Blvd., 5th Floor Dallas, Texas 75207

RE: EX PARTE ANDREW LEE JACKSON: CAUSE NO'S F-91-04916-IL & F-92-02256-IL

Dear Ms. Franklin: On: March 30, 2015, I sent you my:: ~!!JI.'O-lP!R.'{Ifjf!iN»--Dr-·~·PAlGPERl[S & ~·s MOTION FOR AN ORDER APPOINTING AN EXPERT HANDWRITING DOCUMENT EXEAMINER & AFFIDAVIT OF ANDREW LEE JACKSON & EXHIBITS ATTACHED THEREWITH.- to be filed in Court No. ~· As of this date, I have had no reply from you of the filing of the above reference proceedings and/or the Court's ruling in said motions. Please notify me of the status of said proceedings. Thank you for your kind assistance in the above matter.

ALJ/ cc: File ! ' ;..•

... ;

EXHIBIT :0'

ANDREW LEE JACKSON Coffield Unit 2661 FM 2054 Tennessee-·Colony, TX 75AA4

May 11, 2015

COURT CLERK Criminal District Court No. 2 133 N. Riverfront Blvd., 5th Floor Dallas, Texas 75207

RE: EX PARTE ANDREW LEE JACKSON: CAUSE NO'S F=91-04916-IL & F-92-02256-IL

SUBJECT: FAILURE TO RESPOND

ATTN: COURT REPORTER:

On: March 30, 2015, I sent a Motion to your Court Reporter to be filed with Court No. 2· Please see typed-written letter enclosed. I've had no follow-up concerning this Motion in response to the enclosed letter. Please check into this matter and notify me accordingly in regard to my Motion sent to your Court on: March 30, 2015.

ALJ/ Encl. cc: File