John Alan Conroy v. Cliff Harris, Sheriff, Pecos County, Texas, et al.
DueProcess HabeasCorpus Privacy
Whether the withholding of recorded statements by the government violates due process and Brady v. Maryland
Questions Presented : (1) After a criminal defendant's plea of guilty, if it is later found that the government did not live up to the requirements of discovery, is the withholding of multiple recorded statements, : which were ordered by a federal court to be produced for inspection by the defense inder Rule 16 of the Federal Rules of Criminal Procedure, and the recordings are known to law , ; enforcement agents, a violation of Due ‘Process and a violation : under Brady v Maryland, 373 U.S. 83, 83 S.Ct. 1194 (1963)? (2) Does a state (Texas) law enforcement agency have to comply. with an order granted under Rule 16 of the Federal Rules of ; Crimtnat:. Procedure by a federal court, when such agency is in possession of recorded statements are covered by Rule 16, and the recorded statements have direct impact upon the case and decision the defendant made to plead guilty? : (3) Is a civil litigant entitled to appointment of counsel, when > the litigant is not a trained attorney, and does not have ‘any . access to any state laws, rules or procedures and can not : look up relevant case laws, nor afford to pay an attorney, to ‘ properly present his case, and only has access to the federal : laws, rules and procedures since he is an inmate in a federal © prison that is not required to supply any state resources : for this.purpose? : ; ¢ ; . A . (4) Is John Alan Conroy entitled to at least an IN CAMERA review of the reorded videos by the District Judge, as in the joined — case Conroy v Sloan, et al., 2016-523428 (99th District Court, Lubbock County, 2016), where the appellate court ordered a ; writ of mandamus for the interrogation video of Petitioner, John Alan Conroy, directed to the Texas Department of Public 7 Safety? . . (5) Can an appellate court consider evidence contained on a floash drive that the Petitioner did not get to examine, nor : review, and of which was not entered into evidence nor the . record, and was part of a private transaction between Pecos County's attorney and’ the Judge? ; 7 (6) Can a Judgment of Dismissed With Prejudice be proper when the ; case is in pursuit of possible exculpatory or helpful : information, documentation, or materials that could be used . in a federal habeas at a later date, where the Dismissal . with Prejudice would forever bar the inmate from the evidence? . (7) Does the Michael Morton Act (2014), Section 2(k) apply in . this'case with the continuing duty abligation of the state, and does the Michael Morton Act override Texas Governmetn Code § 552.028 as Section (m) of the Michael Morton Act states? . (8) Is there a continuing duty of the Federal Government to hand , . over newly discovered Brady materials to a person who pled ; guilty, if that material would be beneficial to the defendant? ii . .