gi ,azq“@z,@z ,¢~/O:~ January 27, 2015 Tyler, Te. Re: Exparte Ml'chae] Regard Wel)b, Case No’s. 007-0447-l l, 007-0048-11, 007-0449-l l & 007- 0450_11 un the 7"‘ Judi¢iai Dismcr own Ofsmirh Coumy, Texas). `r` Reply to State’s Original and Supplemental Answers to Application for Habeas Corpus Dear Clerk: Enclosed please find the original copy of Applicant Webb’s Reply to State’s Original and Supplemental Answers to his Original Applications for Writ of l-labeas Corpus Applications, to be filed among the papers in the above-styled and numbered causes. Please notify Applicant at his address listed below of the date of filing and disposition of these proceedings Thank you t`or your kind attention to this matter. Sincerely 3 6 / R‘ECE|VE;) lN GOuRToFcRiMiNAL APPEALS FEB 04 2015 / , ’. /’/ h ' ID#01784539 /m. 810 FM 2821 Abel ACOS?§, Clerk Huntsville, Texas 77349 Enclosures CC: ’$* Abel Acosta, Clerk Court of`Criminal Appeals P.O. Box 12308 Austin, Texas 787l l *Z' Aaron S. Rediker Asst. District Attorney Smith County, Texas lOO North Broadway, 4"] Floor Tyler, Texas 75702 Fi|e CASE NUMBER: 007-0450-11-A © © PY EX PARTE § IN THE DISTRICT COURT MICHAEL RENARD WEBB ' § 7TH JUDICIAL DISTRICT APPLICANT, TDCJ-ClD#01784539 § SMITH COUNTY, TEXAS APPL]CANT WEBB’S REPLY TO STATE’S ORIGINAL AND SUPPLEMENTAL ANSWERS TO HIS ORIGINAL APPLICATION FOR WRIT OF HABEAS CORPUS WITH BRIEF IN SUPPORT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, your Applicant, Michael R. Webb, TDCJ-CID#01784539, proceeding in pro se, in the above-styled and numbered cause pursuant to article 11.07, § 3 of the Texas Code of Criminal Procedure, and files this, his Reply to the State’s Original and Supplemental Answer(s) to his Original Application for Writ of Habeas Corpus and in support thereof, would show the Court as follows: I. Jurisdiction The Court has subject matter and jurisdiction over the parties pursuant to Texas Code of criminal Procedure, Article 11.07. et. seq. II. CONFINEMENT & RESTRAINT Applicant was indicted in cause number 007-0450- ll, filed in the 7th District Court of Smith County, Texas, for the offense of possession/manufacture with intent to deliver a l controlled substance, namely cocaine, >lg, DFZ,‘ a second degree felony (enhanced). On March 19, 2012, Applicant, with his two trial attomeys, Mr. Greg Waldron and Ms. Tonda Curry, entered into a non-negotiated plea of guilty in a single hearing2 Based on his plea entered at that time before the Court, the Court found Applicant guilty of the charge alleged in the instant indictment and sentenced him thereafter in a consolidated plea and sentencing hearing to confinement in the Texas Department of Criminal Justice, Correctional Institutions Division (TDCJ-ClD) for thirty (30) years. A direct appeal was taken to the Twelf`th Court of appeals in Webb v. State, No. 12-12-00175-CR, who affirmed the judgment and sentence in an unpublished opinion dated June 25, 2013.3 No Petition for Discretionary Review was filed in this case. Applicant filed his original application seeking a writ of habeas corpus in this case on September 20, 2014, as opposed to Respondent’s claim the same Was filed on October 01, 2014.4 Respondent made a separate answer to the instant state Writ application on October l6, 2014.5 Then, it subsequently made a “consolidated” supplemental response to the instant writ ' This case was as being enhanced with one enhancement paragraph and drug free zone allegation 2 Applicant’s related unadjudicated cases; case number: 007-0448-11 for manufacture/intent to deliver a controlled substance, namely, cocaine >4g <200g, a second degree felony (enhanced) and in case number: 007-0449-11 for manufacture/intent to deliver a controlled substance, namely cocaine