IN THE
NAME AND BY AUTHORITY OF
THE STATE
OF TEXAS:
I, Randall Kelton, hereinafter
referred to as "Complaint," under penalty of perjury, do state that I
have personal knowledge I have good reason to believe and do believe based upon
the following information:
In a phone conversation with Beckworth on the 26th day of March 2009, Beckworth told Complainant that the foreman
was sending the complaints, Complainant had left with Evans. Beckworth told Complaint that the foreman
of the grand jury refused to investigate into the allegations. Beckworth said that the foreman of
the grand jury told him, apparently to t tell Complainant, “You need to file
the complaints with a policing agency so they can investigate the
claims.”
Complainant asked Beckworth, “Who
told the foreman that?”
Without answering, Beckworth went
on to say that, Complainant could not waste the grand jury’s time with
frivolous complaints. Complainant assured Beckworth
that the complaints Complainant filed were not frivolous and again insisted to
know who told the grand jury that it could only hear complaints investigated by
a policing agency and not from a private citizen or a representative of
broadcast media. Without answering Complainant’s question Beckworth ended the phone conversation.
It is unreasonable to consider that the foreman
of the grand jury would come to a conclusion that, on the face of it, is in
direct contravention to the requirement of TxCCP
Article 20.09 (supra). The only reasonable conclusion is that Beckworth gave legal advice to the foreman
concerning the propriety of receiving notice from “some credible person.”
If Beckworth did so counsel the foreman of the grand jury to take an action that is in
contravention to standing law, that rings of a criminal conspiracy between the
foreman and Beckworth to deny Complainant in
Complainant’s right to the equal protections of the laws.
It is unreasonable to consider that the foreman
of the grand jury, not being learned counsel, could be construed to have acted
with a culpable mental state, but rather, acted in good faith reliance on
someone the foreman had reason to believe was competent authority. Beckworth, however, acted with an evil mind toward a bad
purpose by conspiring with the foreman toward a
criminal conspiracy to secret Complainant’s allegations from the body of the
grand jury. (see Criminal Affidavit Section JL attached)
Therefore, I charge that heretofore, and before
the making and filing of this complaint, on or before the 26th
day of November 2011, in Cherokee County and State of Texas, Elmer Beckworth, did then and there unlawfully and
willfully conspire with the grand jury forman to
commit the crimes of Obstruction of Justice and Shielding from prosecution,
in an act of Criminal Conspiracy as defined by Section
15.02 Texas Penal Code.
_________________
Randall Kelton
113 S. Allen St.
Boyd, Tx 76023
512 430 4140