• 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:

  • For the purpose of the instant allegation, Affiant considers it reasonable to construe that the foreman failed to appraise the grand jury panel of the complaints filed by Defendant. 

  • An examination of the minutes of the grand jury as required to be kept by the District Clerk by TxCCP Article 21.22, will reflect no “true bill,” or “no bill” of the officials named in the complaint filed by Defendant.  It must, therefore, be construed that the grand jury did not examine into the criminal allegations made by Complainant.   

  • It is unreasonable to construe that all the members of the grand jury would, at the same time, refuse to perform the one duty they are sworn to perform.  It is more reasonable to presume that, if presented with the complaints, they would have voted to indict or not to indict and such a vote would be reflected in the minutes of the court as required by law. 

  • It is much more reasonable to believe that  Beckworth did counseled the foreman of the grand jury to take an action that is in contravention to standing law.  Such a conversation between Beckworth and the foreman of the grand jury rings of a criminal conspiracy between the foreman and Beckworth to deny Affiant in Defendant’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 Defendant’s allegations from the body of the grand jury in violation of TxPC Section 37.10 (supra) (see Criminal Affidavit Section K  attached)

  • Therefore,  I charge that heretofore, and before the making and filing of this complaint, on or before the   26th day of December  2011, in Cherokee County and State of Texas, Elmer Beckworth,  did then and there unlawfully and willfully secret government documents from the grand jury,  in an act of Tampering With a Government Document as defined  by  Section 37.10 Texas Penal Code.   

  •  

  • _________________

  • Randall Kelton

  • 113 S. Allen St.

  • Boyd, Tx 76023

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  • Notary Stamp

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    Text Box: VERIFICATION
By the signing of this document I, Randall Kelton, do swear and affirm that all statements made herein are true and accurate, to the best of my knowledge and belief .
SWORN TO AND SUBSCRIBED BEFORE ME, ________________________________, on the __ th day of November 2011, which witnesses my hand and seal of office.
Notary signature:  _________________________________

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