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P^/ja^x> of fi/L3ug? tum- to m-t 8isr 4ctj /v /^a fLz^ns?z ^>^PPLZ[WbjT AM Tftut ArJ-o Co.^&orj AjjA, fU^r -X MAPI CAHScg^> A &)£V aF THIS DoluaiI^t TU &*- Sl^ut^ o^ fl-yc ^T)allaa Cjoc^^ry •Lj 'Strict ArTu/gAJir ^c;,m DVt AA^ ^-V. EU^fNga &*.Un~i &V PlAdUC . Q^t/v^ C&lSpisi _^____________ Applicant f#0 5f Jeremy Crespin TDCJ No. 1807429 Hughes Unit Rt. 2, Box 4400 Gatesville, TX 76597 Clerk Court of Criminal Appeals of Texas P.O. Box 12308 Austin, TX 78711 February 28, 2015 RE: WR-82,141-04 and W^-82,141-03 Dear Clerk: PLEASE FILE THE ENCLOSED MOTION IN BOTH OF THE ABOVE REFERENECED CASES (WR-82,141-04 and WR-82,141-03). I Please find enclosed one original of "Applicant's PRO SE Motion for Leave to Suggest Court to Reconsider, On Its Own Initiative, the Denial of Relief in These Writ Application." Please FILE it in both cases and present it to the Court for action. Thank YOU for your time and assistance in this mater Respectfully, Jerer^ CrespinJ' Applicant PRO SE JC/swd cc: FILE DA CCA WRIT NO(S). WR-82,141-03 AND WR-82,141-04 § IN THE COURT OF CRIMINAL EX PARTE § .§ APPEALS OF TEXAS JEREMY CRESPIN § § AT AUSTIN, TEXAS APPLICANT'S PRO SE MOTION FOR LEAVE TO SUGGEST COURT TO RECONSIDER, 'TTg OWN INITIATIVE, THE DENIAL OF RELIEF IN.THESE WRIT APPLICATIONS TO THE HONORABLE JUDGES OF THIS COURT: Applicant, Jeremy Crespin, first received a copy of the convicting court's Findings of Fact and Conclusions of Law ("Findings") on Monday, February23, 2015. This Court denied Felief in these writ applications on Wendsday, February 25, 2015. Those 2 days were not sufficient time for Applicant to file OBJECTIONS to the convicting Court's Findings. Priorly, in a "motion to stay", Applicant had asked this Court to require the convicting court clerk to' provide Applicant with a copy of the Findings. It appears that, rather than resolve that concern in the open, this Court utilized back channel (and ex parte) communications with the convicting court officals and "dismissed" the motion to stay. The result being, that while Applicant (thankfully) received a copy of the Findings, as a pratical matter Applicant was not given 10 days to file OBJECTIONS to those findings (as was requested in the motion to stay). See, Tex. R. App. Proc, 73.4(b)(2). Thus, Applicant request leave to suggest that this Court RECONSIDER, on its own initiative, the denial of relief in these article 11.07 writ cases. See, Tex. R. App. Proc., 79.2(d). And, that upon reconsideration, or rehearing, that this Court consider Applicant's OBJECTIONS to the convicting court's Findings. Primarly, this Court had previously determined that Applicant had alleged facts -that, if true, might entitle him to relief and that additonal facts were needed. See, CCA Order in Writ No. wr-82,141-03 (12/17/2014). Yet., the only additonal facts gathered was trial counsel's "answer" which contains no facts reg-lative to the grounds raised in the writ applications.^ Thus, the Convicting court's Findings are not supported by the writ record before this Court. See. Ex parte Evans, 964 S.W.2d 643, 648 (Tex.Crim. App.l998)("Although the findings indicate that documents ... corr-obrat.e^Appl.ican.t.'.s allegations, our recordjioes not include any such documents. The record is devoid of anp evidence..." to support the trial court's findings.) Worse still, the convicting court puportsto make a credibility determination about, trial counsel; however, even if the convicting court were privy to ! confidential attorney-client communications between trial counsel and other defendants, the advice given to other defendants does 1 not.support Findings on what advice counsel gave to Applicant. See, Pension v. Ohio, 488 U.S. 75,.. .n. '(1988)(very real concern that-counsel can just be lazy in one case is one reason an Anders.brief is necessary). Applicant's OBJECTIONS to the convicin^ court's Findings^f ollow : 1) Irrespective of what happen in.the juvenile court, the convicing court did not have jurisdiction to enter the Judgment of convictin in writ No. WR-82,141-03 because Section 8.07 of the Penal Code prevents prosecution and conviction ofrany one under the age of 15 for a second degree s&d&©iyYand on the date of this offense, as recorded in the Judgment, Applicant was under the age of 15. See, Ex parte Waggoner., 61 S.W.3d. 429, 431 (Tex.Crim.App.2001) 2) An 11.07 writ application seeks relief from a final felony Judgment and, therefore, it is the date of the offense recorded in the Judgment that matters; which, requires that the law in effect on the date of the offense, as recorded in the Judgment, to be applied (and in 1994 Applicant did not have to object, prior to trial, to problems with age restrictions). See, Waggoner, 61 S.W.3d at 431 n.2. 3) The express findings set out on the face of the juvenile court Order limited the transfer to conduct that happen when Applicant was 16 years old; therefore, inspite of any "on or about" language the juvenile court never waived its exclusive jurisdiction over conduct that happen on the date of the offenses, as recorded in the Judgment, and the convicting court did not have any jurisdiction to enter the Judgments of conviction in Writ No(s). WR-82,141-03 and WR-82,14104. See, Moon v. State, No. PD-1215-13 (Tex.Crim.App. - December 10, 2014)(PUBLISHED)(insufficiency of the evidence to be measured by the express.findings set' out on the face of the juvenile court Order); Taylor v. State, 332 S.W.3d 483, 491-492 (Tex.Grim.App.2011) ;. (language in jury instruction could limit the "on or about" dates the jury could consider to dates when the defendant was over 18 years old.) . 4)v Applicant :wasvNOT required to cite law in the writ application, rather law must be cited in the memorandum of law, and in his memorandum of law Applicant did cite to Richardson.v. State, 7.70 S.W.2d 797, 799 (Tex. Crim.App.1989) which relies upon Section 54.02(g) of the Family Code to prohibit the separate prosecution, or rather the retroactive separation of a companion case out of the underlying juvenile court order. See, "Instruction" for 11.07 writ application form (rev.' 01/14/2014) 5) The statue, Penal Code 3.01, itself threatened • stacked sentences of these two separatly indicted cases and, regaurdless of any other promises, by pleading guilty in exchange for 5 years deferred adjudication probation, Applicant avoided.the threatened result. 6) There, is a fourth category, that creates ex post facto laws, mainly laws that "permit conviction on quantum of evidence, where that quantum, at the time the new law was enacted, would have been legally insufficient" ^and under the statue of limitations in effect on the date of these offense^ at the time of trial there would -have—been-"insltf-M-ci-en-t--evidence~t-o-" -SeeT'XafmeTr^v; Texas'; 12 0~~StC r: ~16 2©7" 16"40 (2 000 )-; —- Phillips v. State, 362 S.W.3d 606, 610 (Tex.Crim.App.2011), (acknowledging fourth category); See, also, ie., Lemell v. State, 915 S.W.2d 486, "488 (Tex.Crim. App. 1995) (failure to prove statue of limitaions dates results in reversial for insufficient evidence). 1. Moreover, while the convicting court is allowed to use personal, recollection to resolve disputed facts (under Article 11.07 § 3(d)) — that provision refers to personal recollection about the case at hand NOT any general knowledge the Judge might have, especially when there is nothing in the writ record before this Court to support those findings. See, Evans,. 964 S.W.2d at 648. 7) Trial counsel's "answer" contains no facts relative to the grounds raised in the writ application and, thus, the convicting court's Findings concerning ineffecitve assistance of counsel are not supportted by the record before this Court. See,' Evans, 964 S.W.2d at 648; See also, Perillo v. Johnson, 79 F.3d 441, 4.45, 451 (5th Cir 1996)(additional discovery and evidentiary hearing were required, in part,, when counsel's affidavit did not squarely address the relevant issues). 8) The convicing court made imporoper jumps in logic in its Findings, to include: a) Trail counsel's conduct in other cases proves what knowledge of the law counsel has -g-e-n-e-r-a-1-l-y--,—w-h-at—i-nv-e-s-t-i-ga-t-io-n—co-un-s el "did"itr-t"h"e~s~e-case'syan'd"what— advice- counsel gave to Applicant. b) The fact that trial counsel discussed some unspecified strategies with Applicant proved that counsel actually discussed matters of law that Applicant complains counsel did not in the writ applications. c) The fact that trial counsel was ready to proceed to trial proves that counsel correctly advised Applicant about the guilty plea. d) The fact that Applicant choose to plea guilty proves that trial counsel either did not have to provide adequate advice about the guilty plea or that counsel did provide correct advice. e) That just because Applicant was prescribed anti-psychotic medications that it proves trial counsel was aware of that fact^ and that counsel investigated that fact#$ impact upon Applicant's competency. 9) The convicting court never resolved numerous controverted previously unresolved facts, to include:' a) Was the complainant present and available to testify on June 15, 2010? See, Applicant's Exhibit "A" (Affidaivt of Debra Crespin). b) Did trial counsel tell Applicant whether the complainant was or was not available to testify on June 15, 2010? c) Did trial counsel advise Applicant that the State could obtain a conviction without the testimony of the complainant? d) Did trial counsel advise Applicant that the State could use the "out-cry" statement against Applicaitvt (to obtain a conviction)? e) Did trial counsel advise Applicant that the State could use the recorded phone call between Applicant and the complaintant to either help convict him or at the sentencing hearing to obtain a harsher sentence? f) Regardless of what the plea papers state, did trial counsel advise Applicant that the defferred adjudication probation had severe disadvantages that the 5 years in prison plea bargain did not have? g) Did trial counsel investigate at all the problem with the dates between the juvenile court Order and the indictments and did counsel advise Applicant that if the State only proved at trial the 1994 dates and the defense made the State "elect" which dates it was seeking a conviction for -- that there was a chance to prevent the convietion(s), or at least to prevent a stacked sentence. h) Was trial counsel aware that Applicant had mental helth problems and was taking prescribed anti-p.sychotic medication AND did trial counsel perform any investigation into Applicant's competency? 10) The police believed that Applicant's demeanour during the recorded phone call between Applicant^and the complainant was incriminating and the recording could have been used at sentencing; .therefore, the recording should have been supressed when Applicant had invoked his right to counsel and, thereafter, never waived his right to counsel. See, Rhode Island v. Innis, 100 S.Ct. 1682, 1689 (1980)(anytype of incrimination is suffienct to require suppression). 11) No where does Applicant claim that the registration requirment was an ex post facto violation; rather, at all times,, beeuase Applicant was under the age of 17 on "the date of the offenses., Applicant was only required by law to register once a year -- never every 90 days -- and the appeal was affirmed soley upon the failure to register.. every 90 days (the amendment of the statute of limitaions was a separate error of counsel) AND, insufficient, or no evidence, claims may be raised for the first time on appeal. See, Tex.Code. Crim. Pore, art. 62.001(6) and 62.058. 12) Yet, the convictingc;:crourt failed to aquire a response from revocation counsel or revocation appellate counsel. Thus, not.only are the convicting court's Findings not supported by the record, they continually misconstrue Applicant's grounds forvreliefrand:the applicable law. This Court should not have denied relief based upon the Convicting court's Findings. Indeed, it would be a denial of DUE PROCESS to deny relief based upon such poor Findings. See ie., "Eownsend v. Sain, 83 S.Ct. 745 (1963) (state habeas court must provide full and fair opportunity to develope facts and have the factual basis of calims considered), overruled in part on other grounds, Keeney v. Tamayo-Reyes, 112 S.Ct. 1715 (1992)(n.5 still requires full factual develope in state court proceedings), Ex parte Young, 418 S.W.2d 824 (Tex.Grim.App.1967) (same); See also, (Michael) Williams v. Taylor, 120 S.Ct. 1479 (2000). DISCUSSION OF ONLY TWO OBJECTIONS Rather than represent arguements on each and every one of Applicant's OBJECTIONS, Applicant will ;focus on the convicting court's lack of jurisdiction to enter the Judgments and that the writ record before this Court does not support the convicting court's Findings. (Applicant has filed numerous pleadings addressing the content of the OBJECTION^ to include, a REPLY to the State's Response, A REPLY to this Court's Order of 12/17/2014, a Motion to STRIKE Trial Counsel's Response, and, of course, the original memorandum of law.) JURISDICTION TO ENTER JUDGMENTS The convicting court's Findings appear to conclude that because the "proper" date for the offenses are in September 1996, when Applicant was 16 years old, that these is nothing wrong with these convictions. It is correct that it will be important to focus on the conduct when Applicant was 16 years old. However, the Findings (or conlcusions) overlook that it is the date in the Judgment(s) that will determine if these convictions are improper. Especially, when the only evidence to support the Judgments are the judical confessions that admit to offenses in Septmber 1994 (over which the convicting court had no jurisdiction) Applicant is entitled to RELIEF. Date In Judgments Matter An 11.07 writ application seeks relief from a final felony judgment. See, Tex. Code Crim. Proc, art. 11.07 § 1. The Judgments in these cases record the dates of the offenses, as .required by law, as September 1994. See, Tex. Code Crim. Proc, art. 42.01 §1(14). The only eviednce introduced" at trial were the judical confessions, and they admit to the offenses happening in September -1-9-94-. Thus ,~ the dates, -that, mater in thes.e cas.es — .. 2 are the dates in the Judgment. At this point, the dates in the juvenile court order and the indictment are immaterial. Date in Judgments = Applicable Law The law is already establishes by this Court that for offense^ that happen in 1994, there is no requirment to object to a district court's lack of jurisdiction based upon age-related reasons. See, Waggoner, 61 S.W.3d 431 n. 2. Thus, this Court, and the ^oncivting court, were incorrect to consider whether Applicant objected under Article 4.18(b)(1). That statue does not apply to these Judgment that Applicant is seeking relief from. Judgment in WR-82,141-03 is VOID Moreover, no matter what happen in juvenile court, the convicting court had no jurisdiction to convict Applicant of an offense that happen when he was under 15 years of age. See, Tex. Penal Code § 8.07; See also, Acts 1975, 64th Leg, p. 2158, ch. 693. Thus, this Court's own case law establishes, that the Judgment in Writ No. WR-82,141-03 is VOID. See, Waggoner, 61.S.W.3d at 431. Did "White Card" Overrule Waggoner? This Court should not summarly overrule Waggoner, this Court's established precedent, with a "white card" denied without written order. Application of Legal Theories = WR-82.,141-04 VOID Thus, established precedent requires reflief from the Judgment in WR-82,141-03. Yet, it does take some application of leagal theories to determine that the Judgment in WR-82,141-04 is VOID. There are several legal theories under which to determine that this Judgment is VOID (which have been discussed in privious pleadings); but, only one legal theory will be.addressed here. Moon v. State = Face of Juvenile Court Order Matters Just recently, this Court has held that the express findings set out on the face of the juvenile court's Order are controlling. See, Moon, PD-1253-13 (applying Family Code § 54.02(h)). The face of the juvenile court's Order in these cases expressly set out that the juvenile court was only transfering conduct that happen when Applicant was 16 years old and that happen on or 3 about September 1, 1996. Conduct Not Person Transfered While it is true.that an indictment, and conviction, following a transfer from the juvenile court may be based upon any conduct that the juvenile court transfered -- it is only conduct, not a person, that is transfered. See, Livar v. State, 929 S.W.2d 573, 574 (Tex.App. - Ft. Worth 1996)(following Ex parte Allen, 618 S.W.2d 357, 361 (Tex.Crim.App.1981(Op. on reh'g). Thus, 2. See, Ruiz v. State, 499 S.W.2d 299 (Tex.Crim.App.1973)(under prior version of Article 42.01 the date of the offense did not matter unless it reflected the conviction was barred by statute of liomitaion AND AS LONG AS THE DATE WAS IN AGEEMENT WITH THE JUDICAL CONFESSION).. It could be argued that under the present version of Article 42.01 the date of offense does matter and espcially when it is necceassary to determine the applicable law and other material matters AND that the date in the Judgement must match the JUDICAL CONFESSION. the express findings set out on the-faee of the juvenile court's Order work as limiting language that limits the conduct that is transfered. See, Taylor, 332 S.W.3d at 491-492. Therefore, inspite of any "on or about" language in either the juvenile court's order or the indic^imrt -- the only conduct the convicting court had jurisdiction over was from when Applicant was 16 years old. Id. The juvenile court never waived its exclusive jurisdiction over any conduct that happen in September 1994 (the dates in the Judgments and Judical Confessions). Therefore, the Judgewfrt in Writ No. WR-82,141-04 for an offense that happen on Septmeber 1, 1994 is VOID (as well as the Judg&wrrt in WR-82,1.41(B). Applicant is entitfiled to RELIEF. FINDINGS UNSUPPORTED BY' THE RECORD I. Is there any doubt that even when the state does not have to offer any post-convction relief, that once the state chooses to offer post- conviction relief procedures applicant's are entitled to DUE PROCESS in using those procedures? Applicant has not;i>©e^ ^ afforded DUE PROCESS when the trial court continualy misconstrued his grounds for relief and failed to allow Applicant an opportunity to gather additional evidence to support his grounds for relief. For instance, this Court had priorly determined that Applicant's grounds that revocation and revocatior\fiappellate counsel were ineffective to fail to object to the revocation of probation abased upon the sex offender registration requirments "if true, might entitle him to relief." See, CCA Order in WR-82,141-03 (12/17/2014). Yet, when the convicting court's Findings misconstued that ground as some type of complaint about an ex post facto law, this Court did not revisit its original determination that there was a vaild -VVvose calim made in that grounds* No Facts in Trial Counsel's "Answer" The simple fact is that trial counsel's "answer", that is devoid of any supporting facts, can not support any Findings of Fact. See, Ex parte Reed, 271 S.W.3d 698, 727 (Tex.Crim.App. 2008)(no deference to findings and conclusions that are not supportted by the record). The only "fact" in trial counsel's "answer" is that counsel "was able to secure -[Applicant] a five year probation which he quickly violated." (emphasis added). This fact only serves to affirm, not refute, Applicant's grounds. Applicant's most basic complainant is that trial counsel was so pleased with himself at securing the most lenient, plea bargain allowed by law, that counsel did not fall the need to explain to Applicant little things like the differences between regular "probation" and deferred adjudication probation. In short, counsel's response, shows that, once again, this ease is not impo_-ant enough to merit his precious time to explain the relevant facts and law. How on earth such an "answer" from counsel can support the Findings is lost upon Applicant. Not About Credibility All the convicing court did was. find that trial counsel was creditable. Okay, great. But, what facts did counsel diclose that were creditable? Only the one.-- that he secured the most 3. The juvenile court's Order limits the conduct in WR-82,141-03 to exactly happening on September 1, 1996 (not "on or about"). 4. The record also does not support the convicting court's'finding that,the plea papers explained that if Applicant was placed on deferred adjudication probation he could be sentenced anywhere within the applicable range. First, at the time of the plea Applicant did NOT know the correct termilogy. And what the plea papers actually say is that Applicant was pleaing to "Deferred community supervision for 5 years" and if "unadjudicated community supervision" were violated he could be sentenced anywhere within the range. NEVER DO THE PLEA PAPERS COMBINE THE TERMS "DEFERRED" and "UNADJUDICATED". Thus, Applicant did not understand, from the plea papers, that the "probation" he was agreeing to could result in a LIFE sentece if revoked. ; . -,nnow , . ,. 5. See, Ex parte Imoudou, 234 S.W.3d 866, 871 n.4 (Tex.Grim.App.1992)(a lenient sentece does not refute ineffective assistance), Ex parte Langley, 833 S.W.2dl41, 144 (Tex.Crim.App.1992).(same). lenient plea bargain allowed by law. Thus, the resolution of these cases is NOT about credibility. It is about the lack of facts to support any Findings made by the convicting court. Sure, there are some facts disclosed by the trial record. But, it is those exact proceedings that Applicant has.raised as being Consitutinally infrim. Meaning, whatever, was said on the record and in open court is NOT inline with the previously unknown, and confidential, communications between Applicant and trial counsel. Thus, the trial record does not resolve the disputed facts -- it only makes the facts disputed. It is' the convicif^ court's duty to gather additonal. facts to resolve the disputed facts.Townsend, 83 S.Ct. at 757. CONCLUSION And, that is just what this Court has already had to Order the convicting court to do' -- gather additional.facts. Yet, \ trial counsel's "answer" is not sufficient additonal facts to resolve the controverted, previously unresolved facts material to the legality of Applicant's confinement. Thus, the writ record doeSnot support the Findings made by the convicting court. This Court should reject the Findings of Fact and Conclusions of Law, and rather than deny relief, ORDER the conviciting court to gather additonal facts to resolve the disputed facts (ex. was the complainant present at court and available to testify on June 15, 2012). The failure to do so is a denial of DUE PROCESS (for which the federal courts may. resolve). PRAYER Thus, Applicant, Jeremy Crespin, asks for this Court's LEAVE to suggest that this Court, on its own intiative, RECONSIDER the denial of relief, based upon the convicting court's Findings of Fact and Conclusions of Law WITHOUT A HEARING, :in both Writ No(s). WR-82,141-03 and WR-82,141-04; AND, ANY AND ALL OTHER RELIEF THIS COURT FINDS PROPER IN THE INTEREST OF JUSTICE. Respectfully Submitted, Jeremy-'Crespin ) TDCJ No. 1807429 Hughes Unit Rt. 2, Box 4400 •Gatesville, TX 76597 APPLICANT PRO SE VERIFICATION / CERTIFICATE OF SERVICE I, Jeremy Crespin, TDCJ Id No. 1807429, being presently incarcerated in the Hughes Unit of TDCJ-CID, in Coryell County, Texas, do declare under the penalty of perjury that the^facts inthis motion for leave are true and correct and that I have caused a copy of this motion to be served on the Dallas^County District Attorney on the date executeAbelow by placing it into the prisonmail system to mailed 1st class USPS. EXECUTED on this the Aft day: of Pi ,\q/Way^\ , 2015. Jeremy Crespin A Applicant PRO S:©