FORMAL REQUISITE OF AN INDICTMENT:
THE INDICTMENT FAILED TO PROPERLY ALLEGE THE OFFENSE,AS WRITTEN
IN THE TEXAS PENAL CODE ANN. § 21.02.

INSUFFICIENCY OF THE INDICTMENT:
WHERE INDICTMENT/JURY CHARGE"DO NOT" FACIALLY ALLEGE THE OFFENSE,
THIS REVIEWING COURT MUST TAKE INTO CONSIDERATION "NOT ONLY THE!
INDICTMENT/ JURY CHARGE,BUT ALSO CONTROLLING PENAL PROVISIONS
AND JURY INSTRUCTIONS'.'

SUFFICIENCY CHALLENGES-FACTUAL INSUFFICIENCY:
THE EVIDENCE IS INSUFFICIENT TO ESTABLISH FACTS OF V,CONTINUOUS
SEXUAL ABUSE AGAINST A CHILD YOUNGER THAN 14 YEARS OF AGE" OR
A LESSER INCLUDED OFFENSE OF "INDECENCY WITH A CHILD BY CONTACT"
THAT IS NOT LISTED IN THE ORIGINAL INDICTMENT OF THE COMPLAINT.

FAILURE TO TRACK INDICTMENT IN THE JURY CHARGE:
"NOT TRACKING THE EXACT LANGUAGE OF THE MANNER AND MEANS ALLEGED
IN THE INDICTMENT".

AMENDMENT OF THE INDICTMENT:
TRIAL COURT FAILED TO EFFECTIVELY AMEND INDICTMENT OF PEOPLE'S
COMPLAINT.

FACTUAL SUFFICIENCY STANDARD OF REVIEW:
THIS COURT IS CONSTITUTIONALLYEEMPOWERED TO REVIEW THE JUDGMENT
OF THIS COURT TO DETERMINE THE FACTUAL SUFFICIENCY OF THE EVIDENCE
USED TO ESTABLISH THE ELEMENTS OF THE OFFENSE.

NO EVIDENCE DOCTRINE:
THUS SECURES AN ACCUSED THE MOST ELEMENT'S OE DUE PROCESS RIGHT'S;
"FREEDOM FROM WHOLLY ABITRARY DEPRIVATION OF LIBERTY".v

V.
PREJUDICE :
THIS COURT SHALL HOLD TRIAL COURT ERRED IN ADMITTING THE COMPLAINED
ABOUT EVIDENCE .

HARM ANALYSIS:
"ONE DOES NOT LOOK AT THE TAINED EVIDENCE,BUT AT THE UNTAINED
EVIDENCE"AND ASK'S WHETHER IT ALONE COMPELS A VERDICT OF GUILT.

FIELD ASSESSING THE HARMFULNESS OF A FEDERAL CONSTITUTIONAL
ERROR (S).
WAS THERE OVERWHELMING EVIDENCE OF GUILT ? THAT WAS NOT TAINED/
TURNISHED BY ERROR j|S) .

EGREGIOUS HARM:
REVERSAL IS REQUIRED,SHOULD THE ERROR (S)fWERE CALCULATED TO INJURE
THE RIGHT'S OF THE ACCUSED.

SUBSTANTIAL EVIDENCE/SUFFICIENCY OF EVIDENCE:
THIS APPELLATE COURT MUST DETERMINE WHETHER THE EVIDENCE AT TRIAL
WOULD ENABLE A REASONABLE AND FAIR MINBp PERSON TO FIND THE FACTS
AT ISSUE,THAT THE EVIDENCE WAS SUFFICIENT TO SUPPORT A CONVICTION.

FACTUAL SUFFICIENCY REVIEW:
APPELLANT CHALLENGES THE LEGAL SUFFICIENCY OF THE EVIDENCE TO
OVERTURN HIS CONVICTION AS BOTH EVIDENCE AND TESTIMONY ARE FACT
UALLY INSUFFICIENT.

VARIANCE,PROOF ELEMENT:
THE EVIDENCE IS INSUFFICIENT,BECAUSE OF THE FATAL VARIANCE BETWEEN
THE INDICTMENT AND PROOF AT

Question not identified