CAUSE NO.

17000214

THE STATE OF TEXAS §

§
Plaintiff § IN THE MUNICIPAL COURT
§
v. § CITY OF SCHERTZ
§
MICHAEL THOMAS PAUL § GUADALUPE COUNTY
§
§
Defendant. § STATE OF TEXAS

MOTION FOR REHEARING OF EVIDENTIARY PROCEEDING

AND RECONSIDERATION OF MOTION TO DISMISS WITH PREJUDICE

Defendant, MICHAEL THOMAS PAUL files this motion for rehearing and in support

thereof, respectfully show the Court as follows:

1. Defendant’s character perceeved ggod will and standing in the community has

been defamed due to false testimony by the declarant of information given as fact from an

individual not present to be cross examined. While the court has some discretion in the

application of hearsay testimony which is provided within the guise of an official investigation

that is used to determine credibility of the person being investigated then used by the court as a

basis of truth weather the individual is being truthful in all his assertions of testimony to the

court. If it is provable under rehearing and by cross examination that the hearsay given as

testimony was in fact NOT GIVEN and a false statement made to the court to further the states

position, the entire testimony of the state’s witness must be stricken from the record and the

witness sanctioned for perjury for giving false testimony who will no longer have credibility with

the court regarding testimony given.

2. Defendant will have present at the rehearing, the individual the state’s witness

has claimed provided specific information from a telephone call during the initial investigation

which was given as testimony regarding prior arrests for criminal activity in direct relation to the
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current charge pending, as well as a statement that the individual was informing the State’s

witness during the same telephone call that defendant was providing false information to a police

officer who was conducting an investigation of a crime while the defendant was being detained.

3. Defendant had no availability to disprove the statements made in court during the

initial evidentiary hearing at the time which were not only blatantly false, but prejudiced the

court into believing that the defendant had not only committed the current charge which is a

crime but had been arrested before for the exact same charge giving the appearance of a habitual

violator with no standing as a public service organization registered with the Texas Secretary of

State under the Operations Code Chapter 18.003 because the registration is in the name of the

community emergency response team and not the defendant’s individual name . Defendant will

provide the accompanying letter that was mailed with the registration which is directly addressed

and titled to the defendant as the applicant and recipient of the authorization from the Texas

Secretary of State.

WHEREFORE, PREMISES CONSIDERED, Defendant Michael Thomas Paul

respectfully request that the Court grant this Motion for rehearing of the evidentiary ,proceedings

and reconsider the motion to dismiss for jurisdiction with prejudice, and for such other and

further relief to which they may show themselves justly entitled.

Respectfully submitted,

By: /S/ Michael Thomas Paul

________________________________________

Michael Thomas Paul

(210) 294-4533
Pro Se
DEFENDANT

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 CAUSE NO. 17000214

The State of Texas §

§
Plaintiff. § IN THE MUNICIPAL COURT
§
v. § CITY OF SCHERTZ,
§
§
Michael Thomas Paul § GUADALUPE COUNTY,
§
Defendant. § STATE OF TEXAS.

ORDER MOTION FOR REHEARING AND RECONSIDERATION

On this day, came on to be considered Defendant’s Motion for rehearing and

reconsideration. Having considered the motion and argument of counsel, the court finds that the

motion should be GRANTED.

Accordingly, IT IS HEREBY ORDERED that all named parties must appear in person

and participate in a rehearing of the evidentiary proceedings of this cause.

IT IS FURTHER ORDERED that state’s witness be present for cross examination.

SIGNED and entered this _____ day of May 2017.

JUDGE PRESIDING

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