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53, 151 '@' WRIT NO. WO9-00208-P(A) Ex PARTE § IN THE coURT oF cRIMINAL APPEALS § , § § § SHANE MATTHEw NETTLES § TRAVIS coUNTY,TEXAS APPLICANTS REBUTTAL TQ STATESHREBBUNSE lhe applicant,having considered the States respones,and general denial, make the following written rebuttal, 3 l §PPL;CANT'S REBUTTAL The applicant would like to address States allegation's at this time.State claims applicantahas not provided Sufficient proof to merit consideration of applicant's claims.l understand the burden of proof is on myself being the applicant§l have done my best as a layman at law to draw up the grounds and write the memoranumc of law.As far as providing§legal documents,my hands are somewhat tied.Tex.Gov't Code Ann.§552.028 gives county jails,T.D.C.J. ,and Board of Pardens and Parole the right to deny those records l feel may becneeded topprovide extra proof.Furthermore the State makes claims that applicant challenge to H.B.1433 was specifically addressed in(see Geiken,28 S.W. 3d at;557).ln the case named by the State Geiken's claim was against Judicial review of the boards decision and applicant¥s is not.applicant'saclaim is against how H.B.1433 came into effect and the procedural process used to deny 'as a whole.ln (Teague v. Quarterman
482 F.3d 769)(Sth Cir.2007) at 776 they state parole has a narrowly limited modicum of discretion .lt is also stated in S.B.213 that parole tell applicant inrwritting specifically how and why they came to the decision.ln more then one point in law parolewhas violated my rights concerning the procedural process and continue to abuse thier discretion.ln Teague v. ' Quarterman
482 F.3d 769the 5th circuit also states Texas inmates have a contitional expectancy of early release.When the Board of pardens and Parole took that date,they violate State and Federal Constitutional Law. PRAYER FOR RELIEF Applicant Shane Matthew Nettles.pro'se,resectfully request the Court to forgive applicant for being a layman at law.Applicant humbly ask the Court to grant applicants application for WRIT of Habeas Corpus and make findings for relief on the five grounds in the application. » Respectfully Submitted %@M §hane Nettles #1566038 Movant Pro'Se c/c
Document Info
Docket Number: WR-83,151-01
Filed Date: 5/1/2015
Precedential Status: Precedential
Modified Date: 9/29/2016