"M,L@C?Q~o§ TU: Eourt of Eriminal appeal of Texas PDBUZ TZBUB k CAPITUL\SIATIUN AUSTIN, TEXAS 78711 FRUM: Johnny Q. Elawson,Jr. 1578#31 Terrell 1300 FM 655 Rosharon, Texas 77583 RE: 6th District Court Cause # 22971 HC_%. Dear Sir or Madame, Enclosed is a copy of the rebuttal_to the Statehs Answer to vmv writ of Haheas Corpus 11.07. l received the State‘s answer at legal hail on 5 March,2015 so l answered their answer the same day I received it. So please tile the enclosed Petitioner's Rebuttal of States Answer. Please give me notice as to when this Rebuttal was Filed. Thank you For your time and effort in filing this rebuttal. sincerlv , 444 4) 94444 _ ghhnny'Q. Elawson, r. , Pro se 'RECENE m COURTOFCRNMNALAPPEALS MAR 11 2015 AC@@H A@o§ia, mark EAUSE NU.22971 HCE EUURT UF ERIMINAL APPEAL UF TEXAS \ \ sTATE br TExAs § v. § JDHNNV Q. CLAusbN,JR. PETITIUNER‘§ REBUTTAL UF STATE54ANSwER NBw EUMES, Johnny Q; Elawson, Jr., Prosse pursuant to article 11.07 of the Texas Eode of Criminal Procedure and files this re- g . buttal to States Answer to Petitioner's Application for writnof Habeas Eorpus filed by Johnny Q. Clawson, Jr., the applicant. l . In response to State‘s Answer to Petitioner‘s Application for writ of Habeas Eorpus 11.07, Petitioner restates that all 18 (eighteen) grounds raised on Petitioner's writ of Habeas Borpus are all reversible constitutional errors with all having Suprewe Court documentational rulings to support petitioner's position. Furthermore, ALL grounds does have a stated actioable grounds for relief. Petitioner does raise cognizable claims for Habeas relief as called for in Mc Cain v. State, 67 S.w.3d 2“4 (Tex.Erim. App. §UUZ) which is satisfied since Petitioner raises: 1) ineffective assistance of Trial counsel; 2) prosecutorial misconduct; 3) ju- dical abuse of discretional powers; h; ineffective assistance of appellate counsel. All four (A) of these areas are`areas of 34 constitutional errors which is the base;of this Schlup styled Actual Innocense Claim. The constitutional errors covers 5th,6th, 'and 1hth admendment of the United Btates of America Eonstitution. EETITIBNER"SSBRAYER Petitioner prays this Eourt reads and rules in Petitioner's favor granting an aguittal or remands for a new trial to correct this gravious miscarriage of justice. Plus orders an evidentuary hearing to be held as petitioner petitioned for with the petition- er pysically at hearing in person due to petitioner's heavy relis ance on lip reading to suppliment what he hears of sound thru his hearing aid. vDated: Johnny Q. Clawson,Jr.,#157Bh51 C.T.Terrell Umit 1EUUFM655 Rosharon, Texas 77583 EERTIFIEATE UF SERVIEE l hereby certify that a true and correct copy of the Petition- er's Rebuttal to State‘s Answer to Petitioner's Application for writ of Habeas Eorpus was sent to District Attorney Eary Young at 119 N. Main St., Paris,Texas 75AEU, this day 5th day of March,2015. Johnny Q. Elawsong Jr., Pro se
Clawson, Johnny Quanner Jr.
Combined Opinion