Perry, Ex Parte James Richard "Rick"

Court of Appeals of Texas·Decided August 27, 2015·No. PD-1067-15·Published

Opinion

lOlltS Texas Court of Criminal Appeals P.O. Box 12308 Austin, Texas 78711

"In re Eric Flores , pro se relator"

"In re The State of Texas , relator"

Vs.

Richard James "Rick" Perry , defendant

Trial Court Case No. D-l-DC-14-100139 Third Court of Appeals Case No.3-15-00063-CR Texas Court of Criminal Appeals Case No.PD-1067-15

PETITION FOR AMICUS CARIAE BRIEF IN THE PUBLIC INTEREST OF HEALTH AND SAFETY

(l)Table of Contents COURT OF CRIMINAL APPHALS (2)Parties of Interest (3)Opinions Below ^ 27 2015 (4)Question Presented (5)Constitutional Statutes (^^c^_ c.,>, (6)Jurisdictional Statement (7)Statement of the Case (8)Statement of Facts (9)Summary of Argument (lO)Argument (ll)Conclussion and Prayer

Pleaded By : "In re Eric Flores , pro se relator" General Delivery , 8401 Boeing Dr., El Paso Texas 79910 (2)Parties of Interest

(i)Eric Flores is a party of interest whoms place of business is

designated at General Delivery , 8401 Boeing Dr., El Paso Texas

79910.

(ii)Richard James "Rick" Perry is a party of interest whoms place

of business is designated at 122 C St., NW, Ste. 200Washington,

DC 20001.

(iii)The State of Texas is a party of interest whoms place of

business is designated at State Capitol, P.O. Box 12697 Room

1E.8 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

(4) Questions Presented

(i) Whether the Texas Rules of Evidence no. 402 allows , enables ,

or procurrs 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 relief 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 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 malingered 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 mass murder 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 if 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 Texas Court of Criminal

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 Texas Court of Criminal 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 Texas Court of

Criminal 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 Texas Court of Criminal 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 Texas 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

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