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WR-83,286-01,02 DOCKET NO. __________ IN THE RECEIVED COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS 5/15/2015 AT AUSTIN, TEXAS ABEL ACOSTA, CLERK IN RE: BRANDON JAY CARTER, Relator MOTION FOR LEAVE TO FILE PETITION FOR WRIT OF MANDAMUS AND WRIT OF PROHIBITION TO THE HONORABLE COURT OF CRIMINAL APPEALS: Brandon Jay Carter, Relator, moves this Court to grant him leave to file his Petition for Writ of Mandamus and Writ of Prohibition, and shows: 1. Concomitantly with filing of this Motion, Relator is tendering to the Clerk of the Court his Petition for Writ of Mandamus and Writ of Prohibition. That Petition is incorporated into this Motion, by reference, for all intents and purposes, as though set forth herein verbatim. 2. Relator represents that his Petition for Writ of Mandamus presents an issue of great importance which may be paraphrased as follows: may a judge ignore a defendant’s Due Process rights and this Court’s pronouncements of law by removing appointed counsel on a whim, without 1 a hearing. 3. Relator suggests that this issue is of great importance, not only to him, but to the criminal jurisprudence of Texas. 4. Relator therefore prays that this Honorable Court grant him leave to file his Petition for Writ of Mandamus and Writ of Prohibition. Relator prays for general relief. Respectfully submitted, /s/ D. Chris Hesse David Christopher Hesse S.B.O.T. # 24049081 112 West 8th Avenue, Suite 301 Amarillo, Texas 79101 Tel: (806) 350-6785 Fax: (806) 350-6786 Chris@PanhandleCriminalDefense.Attorney Attorney for Relator, Brandon Jay Carter Of Counsel: L.T. “Butch” Bradt #02841600 14015 Southwest Freeway, Suite 4 Sugar Land, Texas 77478 (281) 201-0700 Fax: (281) 201-1202 ltbradt@flash.net Michael Mowla #24048680 445 E. FM 1382 #3-718 Cedar Hill, Texas 75104 (972) 795-2401 Fax: (972) 692-6636 2 michael@mowlalaw.com CERTIFICATE OF SERVICE I, the undersigned attorney, in accordance with the Rule 9.5, T.R.A.P., certify that a true and correct copy of the foregoing Petition was delivered to: Honorable Thomas R. Culver, III 240TH Judicial District Court Fort Bend County Justice Center 1422 Eugene Heimann Circle Courtroom: Room 3E Richmond, Texas 77469 Becky.Fisher@fortbendcountytx.gov John F. Healey, Jr., District Attorney Gail Kikawa McConnell, Ass’t District Attorney 1422 Eugene Heimann Circle Richmond, TX 77469 Gail.McConnell@fortbendcountytx.gov Harris S. Wood, Jr. 701 North Post Oak Road #425 Houston, Texas 77024 Fax: (281) 579-1586 hwoodatty@yahoo.com On May 11, 2015. /s/ D. Chris Hesse D. Chris Hesse 3
Document Info
Docket Number: WR-83,286-02
Filed Date: 5/15/2015
Precedential Status: Precedential
Modified Date: 9/29/2016