Exhibit 6:

DEFENDANT’S MEMORANDUM OF LAW IN SUPPORT OF HABEAS CORPUS PETITIONS

INDEX

TABLE OF CONTENTS:

• Point A:  The petitioner has proven that his U.S. Const. 6^th Amendment right to a speedy trial was violated on case No. FVA-06241
• Point B:  The petitioner has proven that he was rendered ineffective assistance of counsel which resulted in his conviction, on case No. FVA-06241
• Point C:  The petitioner has proven that his right to go to trial, and Due process of the law, under the 14th Amendment of the U.S. Constitution, was violated when jail officials coerced the petitioner to enter involuntary guilty pleas  on cases FVA-06241 and FVA-10530
• Point D:  Pressuring the petitioner to plead guilty to his criminal case  FVA-06241, by threatening to use ”prior convictions” on cases and crimes that did not occur until after the crimes alleged in  FVA-06241 occurred, was an Ex post facto law application,  in violation of petitioner’s rights under the United States Constitution.
• Point E:  The petitioner did not receive his time served credit for case No. FVA-06241 in regards to the time he was booked and held in Colorado jail on that case.
• Conclusion

TABLE OF CASES:

• Fex V. Michigan, 113 s.ct. 1085, 1087 (1993)
• People V. Cella, 114 Cal. App.  3d 905, 917-18 (1981)
• United States V. Mauro, 436 U.S. 340, 359, 98 s.ct.1834 (1978)
• People V. Rhoden, 216 Cal. App. 3d 1242, 1251 (1989)
• People V. Castoe, 86 Cal. App. 3d 484, 487 (1978)
• Tinghitella V. State of Cal., 718 F.2d 308, 312 (9th cir.1983)
• Hughes V. District Court, 593 P.2d 702, 706 (Colo.1979)
• Peyton V. Rowe, 391 U.S. 54, 88 s.ct.1549 (1968)
• In Re. Alvernaz, 2 Cal. 4th 924, 934 (1992) (A, B, C)
• In Re. Clark, 5 Cal. 4th 750, 766 (1993)
• Glass V. Vaughn, 65 F.3d 13 (3rd cir.1994)
• Brady V. United States, 397 U.S. 742, 749,  90 s.ct. 1463, 1469 (1970)
• Colorado V. Connelly, 107 s.ct. 515 (1986)
• People V. Magallanes-Aragon, 948 P.2d 528, 531 (Colo.1997)
• Schneckloth V. Bustamonte,  93 s.ct. 2041, 2047 (1973)
• Reck V. Pate, 367 U.S. 433,  81 s.ct. 1541 (1961)
• Ridge V. Turner, 444 F.2d 3, 4 (10th cir.1971)
• Myers V. District Court, 518 P.2d 836 (1974)
• Zaragoza V. Department of Rev., 702 P.2d 274 (Colo.1985)