•/+ PD-1103-15 COURT OF CRPWAL APPEALS RECEIVED IN AUG 27 2015 The Sixth Court District of App^fJSI3--N0, 3l AC0S»3,w!«« AU6 1 7 2015 HARK ANTHONY YOUNG IN THE SIXTH Texarkana, Texas * Debra Autrey, ClerK VS. * COURT OF CHXMI3AL APPEALS

Till STATS OP TEXAS * iiUHT 60UHTY, TEXAS

SSQU23T FOR COURT APPOINTED G0UH8SL FILED IN PUH8UAST TO AHTICLS 1,031, TEXAS COD1 OF dH3^4IF*i!ttSttl^PPEALS AUG 27 2015 TO THE HONORABLE JUDGE 0? SAID COUBTi Abel Acosta, Clerk COMES NOW, the Petitioner, Mark Anthony Young, TDO.T#l929961, and requests the Court appoint counsel to assist him in filing potitfeon for discretionary review and habeas corpus in the above-styled cause pursuant to Texas Code of CriBiinal Proce dure, article 1*051. Article 1.051(d) atatas as follows»,,An eligible indigent defen dant is entitled to have the trial court appoint an attorney to represent bia in the following appellate and postconviction habeas corpus natters: (l) an appeal to a court of appealsj (2) an appeal to the Court of Criminal Appeals if the appeal is nado directly from the trial court or if a petition for discretionary review has been granted* (3). a habeas corpus proceeding if the court concludes that the inte rests of justice require representation* (4-) any other appellate proceeding if the court concludes that the interest of justice require representation.

Aa the Defendant, in the above-styled ciuse postconviction proceedings, he was constrained to respond to an Anders brief, whereas, he has no physical access to research and review his case in compliance with the requirements of ANDEE0 vs. CALIFORNIA, 336 U.S. S.Ct. 1395, 18 L.2d.2d '+93 (1966) and GAIHOU9 vs. STATE. *06 S.W,2d 137, 138(Tex,Crim.App. I969). These ease laws are not available to the Petl- tione?.'/Defeivi?.'.rb. Also not available to the Petitionsr/Defendant is tne Texas Con stitution, which is a crucial material to his stats conviction, for the Texas Con stitution provides benefits for the Petitioner/Defendant that the United States Constitution doers not (which he has physical access to). The above forgoing case laws and the Texas Constitution has been excluded from the Michael Unit Law Library as communicated and expressed to hira by the Senior Warden, Eddie Baker* and Law Library Supervisor, Ms. Stotts, they said these will not be raads available to Inmates no r-+

matter what litigation the prisoner is in...including post-conviction criminal litigations, Without any physical access to these legal materials, the Petitioner/ Defendant rights to access to courts has been detrimentally abridged. Under the Board Policy Number BP-03.81 Rules Governing Offender Access to Courts, Counsel, and Public Officials states in part that, "...Offenders nay present any issue, including challenges to the legality of their confinement...." This Polioy was systeraatically passed at the time the above foregoing case laws and the Texas Constitution was available (April 20, 2012). Since September 2013, these wore excluded procedurally and systematically via the Michael Unit k& Library which conflicts with Texas Government Code sections ^92.013(a), ^5.025, 499.102(a)$12) and LSWI3 vs. CASEr. 513 U.S. 3^3, 35^355. 116 S.Ct. 217*1-, 2181-2182, and the VISiHIiA CONyBfiTIOK 03 COIBULAR HALATIONS AND OPTIONAL PBaTOOOLS. article 36. and BQIMB vs. StUTtl. 430 U.S. 817, 97 S.Ct. 1^91, 5Z L.Ed.24 ?Z (1977). Petitioner/ Defendant's Declaration in Support of flight to Representation of Counsel is attached and incorporated hereto as Sxibit 1.

Respectfully submitted,

teJLuMjJk Marie Anthony/ Young, Pro se I92996I, Michael Unit 266*fr F.K. 205^ Tennessee Colony, TX 75886 (903)-928-23il//AX-926-2197 EC« File

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