Luis Ray Jaramillo, Jr. v. Lorie Davis, Director, Texas Department of Criminal Justice, Correctional Institutions Division
1. Where Petitioner's state-trial court counsel did not pursue Petitioner's wishes, commands, and orders to file a second-perfected-appeal after Petitioner personally made objections to the trial court judge's' amending the terms of the original plea deal and imposing conditions-of-probation that were not reasonably related to the offense of sex offender registration in retaliation for appealing prosecutorial misconduct once before; where Petitioner's 'state-trial court counsel' did not object to then mental-treatment for Petitioner was ordered by the same judge; where Petitioner's state-trial counsel disclose -to the trial court that the Petitioner suffered "issues of incompetence" but only mentioned during the revocation hearing that "Petitioner had a talent for upsetting everyone"; where Petitioner's 'state-trial court counsel' was not prepared neither reasonably competent to render effective representation to the sudden and instant "First Amended Motion To Revoke" which was introduced for the 'first-time' at the "revocation hearing" inviolation of due process and Petitioner's not objecting to the "First Amended Motion To Revoke" filed in violation of due process by Prosecutor-Christopher Demartino; was such Petitioner denied his 'Sixth -Amendment effective assistance of counsel, where...did not state-trial court counsel right to (1) his counsel did not pursue his wishes, commands, and order to enter an appeal so appe 11 ant-counse 1 could be appointed to pursue abuse of discretion of amending objections to 'trial court judge's the terms of the original plea deal and imposing conditions of probation that were not issued before, and not reasonably related to the offense he was on probation for, but imposed and ordered by trial court judge in retaliation for appealing prosecutorial misconduct, and (2) where his counsel made No objection to his restoration of competence by 'competency-hearing-judge ' but the 'same judge' ordered and imposed mental-health-treatment, and (3) where his counsel did not disclose to the trial court that he suffered "issues of incompetence" but only mentioned during the revocation hearing on 'November 13,2014', that "he had a talent for upsetting every one", and (4) where his'counsel knew he was not prepared for the "First Amended Motion To Revoke" which was filed in violation of due process and introduced on the day of the revocation hearing in violation of the due process of legal notice to prepare a defense and neither did his counsel object to the "First Amended Motion To Revoke" filed in violation of due process of 1a u ?
2. Where Petitioner's appellate counsel did not inform Petitioner of the right to submit a "pro se appellant's brief" during the "first-Assistant-District Attorney's trial judge's' orally fraud appeal-attempt" to ascertain the of altering the trial court records and the pronounced judgment and sentence, to correct the court-records/sentsn- cing-court-records ; where Petitioner's 'appellate counsel' was ineffec tive for submitting inadequate briefs during "both appeal-attemts" where neither brief referred to anything in the record that could arguably support an appeal; where Petitioner's failed to raise insufficient evidence and for not perfecting an "appellant's brief for appeal" upon Petitioner's request and order; Sixth-Amendment' right to effectiveappellate counsel was such Petitioner denied his assistance of counsel on appeal, where... appellate counsel did not
Where Petitioner's counsel did not pursue his wishes to file an appeal, was he denied effective assistance of counsel?