5th Court of Appeals
FILED: 10-21-15
Lisa Matz, Clerk
RECEIVED IN
COURT OF APPE^'S 5th OIST
OCT 1 9 2015
05-14-01386-CR LISA M„.z
CLERK, 5th DISTRICT
IN THE COURT OF APPEALS
FOR THE FIFTH DISTRICT OF TEXAS
AT DALLAS FZLED XIM
Court of Appeals
-0£UiL2015
^ Lisa Matz
SHEYENNE LILES, Clerk, 5th District
Appellant
v.
STATE OF TEXAS,
Appellee
Cause No. F13-71006-Q
On Appeal from Criminal DistrictCourt, No. 204 of Dallas County, Texas
The Honorable Tammy Kemp, Judge Presiding
APPELLANT'S PRO SE RESPONSE IN OPPOSITION,
OBJECTION TO COUNSEL'S ANDERS BRIEF, and
NOTICE OF SUPPLEMENTAL AUTHORITY
SHEYENNE LILES,
Appellant, Pro Se
TDC# 01956109
Murray Unit
1916 NHwy 36 Bypass
Gatesville, TX 76596
TO THE HONORABLE JUSTICES:
Sheyenne Liles, pro se, brings this Response in Opposition, Objection to Counsel's
Anders Briefand Notice of Supplemental Authority. In support thereof, Appellant cites the
below listed points oferror in favor of Appellant and arguable grounds for relief:
1) Appellant's trial transcripts were confiscated by prison authorities on September 29, 2015
and she was thus denied access to the transcripts at a critical stage ofthe appeals process;
2) Appellate counsel's conclusion that trial counsel rendered effective assistance of counsel
is in error in that prior to, during and post-trial, all critical stages of the proceedings, trial
counsel's actions and inactions fell below the necessary standard of competence required
by STRICKLAND v WASHINGTON. 466 US. 668 (1984), all to Appellant's
demonstrated prejudice;
3) Appellant received ineffective counsel when trial counsel failed to challenge the
indictment and where the indictment was vague and insufficient to advisethe common
citizen as to what conduct was proscribed;
4) Specifically, Appellant was denied a fair trial when, despite Appellant's specific requests,
trial counsel failed to obtain a separation of trials from co-defendant;
5) Appellant was denied a fair trial when trial counsel bullied, threatened and insisted that
appellant not testify, despite Appellant's numerous statements that she wanted to tell the
jury that she was under the influence of a violent pimp since her early teens and that she
received multiple beatings that resulted in contusions, a broken jaw, 2 broken teeth and a
hairline fracture;
6) Appellant was denied a fair trialand sentencing when counsel failed to object to the
conviction and where thejury failed to make a specific finding that a "deadly weapon"
was used, thus making a 3 G finding improper;
7) Appellant was denied a fair trial when trial counsel failed to adequately impeach the
State's sole witness against her based upon promise of leniency affecting her credibility
and veracity;
8) Appellant wasdenied a fair trialand fairsentencing where trial counsel failed to
subpoena and call as witnesses both at trial and sentencing persons who could verify and
prove that the Appellant was tortured and beaten as a teen into submission by her vicious
pimp;
9) Appellant wasdenied a fair trialand sentencing where trial counsel failed to document
before thejury her substantial efforts to flee herpimp and starta new life;
10) That trial counsel erred in failing to adequately argue at sentencing against the excessive
sentence finally handed down, which sentence punishes the victim and rewards the actual
perpetrators;
11) That considering the failure oftrial counsel to present all available mitigating and
exculpatory evidence and the failure of the state to seek out the truth, there was not
legally sufficientevidence to support Appellant's conviction,JACKSON v VIRGINIA.
443 US. 307 (1979);
12)That appellate counsel was derelict in her responsibility to communicate withthe
Appellant in that despite several initiatives, appealscounsel failed to communicate with
Appellant at any time.
CONCLUSION
Wherefore, Appellant objects to the filing of the Anders Brief, andrequests that the Court
review the trial record, reverse the conviction and remand for a new trial.
Respectfully Submitted
^nmvMrmhi
Sheyenne Liles, Pro Se
> fO*9-jots
No. 01956109
Murray Unit
1916 NHwy 36 Bypass
Gatesville, TX 76596
CERTIFICATE OF SERVICE
This is to certify that on October Q_, 2015, true correct copies ofthis Pro Se motion was
mailed to: Clerk, Court of Appeals, 5th District of Texas at Dallas, 600Commerce St.,
Suite 200, Dallas, TX 75202, the Appellate Division ofthe District Attorney's Office,
133 N Riverfront Blvd., Dallas, TX 75207 by first class mail, and deposited in the prison
mail receptacle at TDC, Murray Unit, 1916 N Hwy 36 Bypass, Gatesville, TX 76596
fpftgr
SheyennejLiles
r>&. HBxi.Xioai(ka
<\X£fAMJ$L
^jjiXsLmsyx 0
iS^hkb^
LzILk.
t^XsuuAjK. \Shau fc-Tmcui- _t£>
fid. 5^._oi^do cMim^-, _
K3l