ANDREW LEE JACKSON #621203
Coffield Unit
2661 FM 2054
Tennessee Colony, TX 75884
AUgUSt 24, 2015
Clerk
Court of Criminal Appeals
SUpreme Court Building
201 w. 14th Street - Rrn 106 RECEIVED IN
COURT OF C~MINALAPPEALS
Austin, Texas 78701
SEP 0 ·1 2015
RE: ANDREW LEE JACKSON VS. CARTER THOMPSON, Respondent
WRIT OF MANDAMUS
~Atosm, Oterk
Dear Clerk:
Please find enclosed the original copy of my Writ of Mandamus to be filed with
The Court of Criminal Appeals.
Thank you for your assistance in this matter.
ALJ/
Encls.
cc: File
IN THE
..
COURT OF CRIMINAL APPEALS
OF
THE STATE OF TEXAS
§
ANDREW LEE JACKSON, §
Relator, Pro Se §
§
§
vs. § CAUSE NO'S F-91-04916-IL &
§ F-92-02256-IL
§
CARTER THOMPSON, §
CRIMINAL DISTRICT JUDGE, §
.,.;..:
CRIMINAL DISTRICT COURT NO. ~ §
DALLAS COUNTY, 'TEXAS §
Respondent
PETITION FOR WRIT OF MANDAMUS
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
Comes now Andrew Lee Jackson, relator, and files this application
for Writ of Mandamus directing Carter Thompson, respondent, to Rule on
Applicant's Motion For An Order Appointing An Expert Handwriting Document
Examiner in the above Cause Numbers. In support of this application,
relator shows the Court the following:!
I.
On: March 30, 2015, relator filed an Motion For An Order Appointing An
Expert Handwriting Document Examiner to examine and attest to findings
of deliberate forgery of the original Arrest Warrants in the CaH§e Numbers
by the Affiant, Richard Bender, a Police Detective of Grand Prairie, Texas,
who knowingly forged said instruments, which said discovery recently made
of this flagrant outrageous police misconduct established in Applicant's.-
-1-
Motion along with factual (recent) Exhibits in order to comfirm said
forgery by An Handwriting Document Examiner in order to present further
proceedings of this newly discovered evidence extablished by an handwrit-
ing document examiner with Habeas Corpus proceedings to this Honorabi~
Court without any further impediment of Court No. ~ of Dallas County in
pursuant to Article 11.07 §3(d), 26.04, 26.05, 1.051(d)(3), 1149, and
the opening clause of 28 u.s.c.A. 2254 (e)(2), as stated in Applicant's
Motion For An Order Appointing An Expert Handwriting Document Examiner-
filed on: March 30, 2015 in Court No. 5.
II.
Relator would sho~ this Honorable Court that he has on (2) occassions
inquired of the Dallas County Court No. ~ of the status of the above
stated Motion without ever receiving any type of response. SEE~ Exhiibts
~-1 & 1, attached herewith.
SUPPORTING ARGUMENT:
III.
The relator has no adequate remedy of law to pursue the requested
relief other than this application.
IV.
This Court has jurisdiction to issu~ a Writ of Mandamus in this Cause
under Article 5, Section 5 of the Texas Constitution and Article 4.04
of the Code of Criminal Procedure.
WHEREFORE, relator prays the Court grant this Application and issue
. I
a Writ of Mandamus directing Carter Thompson, !criminal District court_
2-
'
..
''
I
I
I
No. ~of Dallas County, Texas, Respondent to Rule on Applicant's Motion
I
For An Order Appointing An Expert Handwriting iDocument Examiner in Cause
. I
Numbers F-91-04916-IL & F-92-02256-IL, filed with that court on: March
I
30, 2015, and any other relief this Honorable !court may deem neccessary
I
SE
Andrew Lee Jackson #621203
Coffield Unit
2661 FM 2054
Tennessee Colony, TX 75884
DECLARATION
I, Andrew Lee Jackson, TDCJ-ID N0.621203, presently incarcerated in
the Texas Department of Criminal Justice-Institutional Division verify
and declare under penaly of perjury the foregoing statements are true
and correct.
on•;&rv-,:i ~""/_ ,
Executed 2015
/sl~_/~--r-r---~
ANDREW LEE JAC
PRO SE
CERTIFICATE OF SERVICE
I vertfy that a true and correct copy of this instrument was mailed
to the Respondent by way of Jhe Da~las District Clerk's Office by 1st
class u.s. Mail on thi~;/~ day of August, 2015.
Page Three/Final
EXHIBIT~
ANDREW LEE JACKSON #621203
Coffield Unit
2661 FM 2054
Tennessee Colony, TX 75884
April 27, 2015
Victoria Franklin
Official Court Reporter
Criminal District Court No. ~
133 N. Riverfront Blvd., 5th Floor
Dallas, Texas 75207
RE: EX PARTE ANDREW LEE JACKSON: CAUSE NO'S F-91-04916-IL & F-92-02256-IL
Dear Ms. Franklin:
On: March 30, 2015, I sent you my:: ~!!JI.'O-lP!R.'{Ifjf!iN»--Dr-·~·PAlGPERl[S & ~·s
MOTION FOR AN ORDER APPOINTING AN EXPERT HANDWRITING DOCUMENT EXEAMINER & AFFIDAVIT
OF ANDREW LEE JACKSON & EXHIBITS ATTACHED THEREWITH.- to be filed in Court No. ~·
As of this date, I have had no reply from you of the filing of the above reference
proceedings and/or the Court's ruling in said motions.
Please notify me of the status of said proceedings.
Thank you for your kind assistance in the above matter.
ALJ/
cc: File
! '
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...
;
EXHIBIT :0'
ANDREW LEE JACKSON
Coffield Unit
2661 FM 2054
Tennessee-·Colony, TX 75AA4
May 11, 2015
COURT CLERK
Criminal District Court No. 2
133 N. Riverfront Blvd., 5th Floor
Dallas, Texas 75207
RE: EX PARTE ANDREW LEE JACKSON: CAUSE NO'S F=91-04916-IL & F-92-02256-IL
SUBJECT: FAILURE TO RESPOND
ATTN: COURT REPORTER:
On: March 30, 2015, I sent a Motion to your Court Reporter to be filed
with Court No. 2· Please see typed-written letter enclosed.
I've had no follow-up concerning this Motion in response to the enclosed
letter.
Please check into this matter and notify me accordingly in regard to my
Motion sent to your Court on: March 30, 2015.
ALJ/
Encl.
cc: File