FILED IN COURT OF APPEALS
IN THE COURT OF APPEALS
12th Court ofAppeals District
TWELFTH DISTRICT OF TEXAS
TYLER, TEXAS
TYLER TEXAS
PAM ESTES, CLERK
In re JUAN ENRIQUEZ, Relator
Original Proceeding from Anderson County, Texas
369th Judicial District, No. XXX-XX-XXXX
Honorable Bascom W. Bentley, III, Presidina
RELATOR'S MOTION TO PROCEED WITHOUT THE RECORD
TO THE HONORABLE JUDGES OF SAID COURT:
Relator moves the Court to allow him to prosecute his
Original Petition without the record, averring as follows.;
The Relator does not have the funds to purchase the record,
but it would not matter if he did because the Anderson County
District Clerk has never replied to any of Relator's requests
or efforts to purchase any documents from the clerk.
II.
No litigant before this Court should have to put up with a
district clerk who does not do her job to the point that as a
matter of routine she violates the rules by not providing prisoner
plaintiff's with judgments entered against them.
III.
The record is already before this Court in
No. 12-15-00225-CV, Juan Enriquez v. Brad Livingston, and the
Court has been requested to take judicial notice of its own
records.
WHEREFORE, PREMISES CONSIDERED, Relator prays that'-his
motion be granted and that he be allowed to proceed in this
action with the record already before this Court in
No. 12-15-00225-CV, supra.
Respectfully submitted,
n Enrique"?3 ~~7
!7122
TDCJ-Michael
2664 FM 2054
Tennessee Colony, TX 75886
Verification
I, Juan Enriquez, declare under penalty of perjury, that
the foregoing statements in the above motion are true and
correct. Executed on December 8, 2015.
an Enriqjj.ez
Certificate of Service
I, Juan Enriquez, certify that a correct copy of the above
motion was served by placing same in the United States mail,
postage prepaid, on December 8, 2015, addressed to Bascom W.
Bentley III, Judge, 369th District Court, 500 N. Church Street,
Palestine, TX 75801 and Brianna Webb, Assistant Attorney General,
P. 0. Box 12548, Austin, TX 78711.