ACCEPTED 01-15-01059-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 01-15-01059-CV 12/15/2015 11:50:18 PM CHRISTOPHER PRINE CLERK First court of appeals Harris county Texas FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS Fannin Houston Texas 12/15/2015 11:50:18 PM CHRISTOPHER A. PRINE 77002 2066 Clerk
Cause#01-15-00689
Petition for mandamus relief
Petitioner Huong Bui vs Texas department of family and protective services is seeking relief in the above styled cause due to abuse of discretion by trial judge hon Michael Schneider of the 315 th district court Harris county Texas
1 wishes to show the judge did not follow case law that would have been of use to rule out the allegations in this case by bypassed and allowed testimony that led to the fabrication of allegations that had no merit nor based on law the petitioner believes her rights to fair due process were strictly violated in this case and is seeking emergency relief in her petition Furthermore the court fail to abide by the rights of the respondents to have fair and adequate counsel for their defense do to miss representation from court appointed counsel the respondents were deprived of their right to a fair hearing and presentation of their defense under color of law we are seeking emergency relief of the orders sign on 11-03-2015 to which the Texas department was awarded temporary managing conservator of the petitioner’s new born child born 01-02-2015
4 petitioner is a foreigner and is not able to understand laws and procedures therefore was strictly deprived of a proper defense in this matter based on allegations that were coerce and forced on her to admit to the department of children’s protective services who used the child as a way to force the mother into a state of duress and violated her civil rights to have an attorney present during any signing of papers or questioning buy state investigators the department was strictly in violations of petitioners rights as per laws to ignore the petitioners request not to sign papers that would jeopardize her child and her rights under laws of state of Texas
5 Furthermore the PETITIONER BELIEVES THAT THE TRIAL COURT WAS NEGLEGENT AND DID NOT ACT TO ACKNOWLEGED THAT THE INVESTIGATOR FOR THE Texas DEPARTMENT OF FAMILY PROTECTIVE SERVICES “NYESHIA BRYENT” ACTED WITHOUT REEGUARD TO THE LAW OF FALSIFYING HER AFFIDAVID AND DID NOT FOLLOW THE LAW THAT WOULDS HAVE AFECTED THE OUT COME OF THE CASE UNDER DUE TO HER FALSIFYING STATEMENTS TO THE COURT UNDER; SEC.37.03. AGERVATED PERGURY A PERSON COMMITS AN OFFENCE IF HE OR SHE COMMITS PERJURY AS DEFINED IN SECTION 37.02. OF Texas CODES OF PROCEEDURERS AND THE FALSE STATEMENT 1. IS MADE DURING OR IN CONECTION WITH AN OFFICIAL PROCEEDING; AND 37. 03 37.04 37.05 37.06 ^ THE COURT IS SET FOR STATUS HEARING 12-16-2015 AT 9:00 AMWE THE PETITIONER ARE SEEKING AN EMERGENCY STAY IN THIS MATTER AND ASK THAT THE 1 FIRST COURT OF APPEAL INTERVEIN IN THIS MATTER WE PRAY THAT THE COURT WILL GRANT OUR REQUEST IN THIS MATTER AND WILL PREVIDE FOR A FAIR AND JUST CONCLUSION
I THE PETITIONER AM PRO SE CAN ONLY ASK THAT A STAY BE PLACED ON PROCEDING SO I CAN INSURE THAT MY RIGHTS ARE PROTECTED BY STATE CIVIL LAWS AND RULES RESPECTFULLY SUBMITTED
HUONG BUI PETITIONER 12-15-2015 HUONG BUI
CERTIFICATE OF SERVICE FORM I DECLAIR ALL PARTIES HAVE BEEN GIVEN A COPY OF THIS PETITION AS PER RULES OF SERVCIE OF STATE OF Texas CIVIL PROCEDURES
SERVICE SENT BY FAX__________________________________ NUMBER____________________________________________ FAX TO ______________________________________________ DATE___________________TIME -----------HUONG BUI__HUONG BUI