CAUSE NO. 01-13-00415-CR, 01-13-00416-CR, 01-13-00417-CR
JAVIER NOEL CAMPOS * IN THE COURT OF APPEALS
Petitioner *
* FIRST JUDICIAL DISTRICT
VS. *
* HOUSTON, TEXAS
THE STATE OF TEXAS * ,Sr *ie0lN
Respondent * %?J^
^r*
MOTION FOR REHEARING PURSUANT TO TRAP RULE 49.1 ^££ -9
20f5
TO THE HONORABLE JUDGE OF SAID COURT: ^ Sr°p^4
COMES NOW, JAVIER NOEL CAMPOS, Petitioner in the above entitled and
numbered cause and respectfully moves this Honorable Court to order a new
hearing pursuant to TRAP Rule 49.1 and would show the Court the following:
I
Petitioner filed a timely notice of appeal. Petitioner filed his Appellant
brief on April 15, 2014 and the State filed the Appelle brief on September 5,
2014 The Court affirmed Petitioner's conviction and issued it's opinion on
January 13, 2015.
II
The State, in it's brief, misconstrued the facts and law to the Court and
painted a false factual picture that contributed to the Court's ruling.
Ill
The Court has made it's ruling against established state and federal law
in a way that conflicts with the applicable decisions of the Court of Criminal
Appeals and the Supreme Court of the United States.
IV
The Court's ruling is a denial of fundamental and Constitutional rights
that result in a miscarriage of justice.
page 1 of 2
PRAYER
WHEREFORE, PREMISES CONSIDERED, Petitioner respectfully prays that this
Honorable Court order a new hearing pursuant to TRAP Rule 49.1 to reconsider
Petitioner's grounds for appeal.
Respectfully Submitted,
Javier N. Caflfpos-Petitioner
Pro Se Representation
TDCJ No. 1854678
Stiles Unit
3060 FM 3514
Beaumont, TX. 77705
CERTIFICATE OF SERVICE
I, Javier N. Campos, certify that a true and correct copy of the foregoing
Motion was mailed to the Harris County District Attorney, 1201 Franklin, Suite
600, Houston, Texas 77002 on this 26th day of January, 2015.
Respectfully Submitted,
Pro Se Representation
page 2 of 2
FILED IN
«STCOURT OF APPEALS
HOUSTON, TEXAS
Javier Noel Campos
TDCJ No. 1854678 FEB -2 2015
Stiles Unit CHRIS Av. PRIN6
3060 FM 3514
Beaumont, TX. 77705 CLERK
January 26, 2015 » «
*<*'
Clerk
Court of Appeals
First Judicial District
Houston, TX.
Re: Motion for Rehearing
Dear Clerk:
Enclosed please find Motion for Rehearing pusuant to TRAP Rule 49.1. Please
file the motion and bring it to the attention of the Court for consideration.
Also, please find one copy and date-stamp it and return it to me in the SASE.
If you have any questions please feel free to contact me at anytime at the
address above.
Thank you for your time and assistance.
Respectfully Submitted,
A &Ji
Javier N. Camnos^Petitloner
Pro Se Representation
CC:
Campos File
0S
Clerk
"2 2015
P"ER A. PR(NE
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HIED IN
ȤTCOURT OF APPEALS
" ISTON, TEXAS
FEB^\2015
HRISTOPHER a\rine
ERK.