Joliet, Kevin Richard ( 2015 )

WR-84,279-01
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/2/2015 6:07:56 PM
Accepted 12/3/2015 8:19:11 AM
ABEL ACOSTA
No. ___________________ CLERK
RECEIVED
IN RE: § IN THE TEXASCOURT
COURTOF CRIMINAL APPEALS
KEVIN RICHARD JOLIET § 12/3/2015
ABEL ACOSTA, CLERK
Relator §
§ OF CRIMINAL APPEALS
MOTION FOR LEAVE TO FILE APPLICATION
FOR WRIT OF PROHIBITION
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW KEVIN RICHARD JOLIET, by and through Wes Ball, his
attorney of record and files this Motion for Leave to File Application for Writ of
Prohibition and in support thereof would show the Court as follows:
I.
Contemporaneous with the filing of this motion is being filed movant
Joliet’s Application for Writ of Prohibition. This Court has jurisdiction for such
writ application pursuant to Article 5, §5(c) of the Texas Constitution which
provides:
Subject to such regulations as may be prescribed by law, the Court of
Criminal Appeals and the Judges thereof shall have the power to issue the
writ of habeas corpus, and, in criminal law matters, the writs of mandamus,
procedendo, prohibition, and certiorari.
This case is a criminal law matter involving the proposed incarceration of a felony
probationer. The writ application complains of future proposed actions by a trial
court and thus a writ of prohibition is the appropriate legal process to seek relief.
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The writ application is being filed as the Relator has no adequate remedy at
law, is clearly entitled to relief.
WHEREFORE, PREMISES CONSIDERED, movant Joliet request leave of
this Court to file his Application for Writ of Prohibition and for such other and
further relief to which he may be entitled.
Respectfully submitted,
/s/ Wes Ball
WES BALL
4025 Woodland Park Blvd.
Suite 100
Arlington, Texas 76013
Email: WBnotices@ballhase.com
Telephone: (817)860-5000
Fax No.: (817)860-6645
State Bar No. 01643100
ATTORNEY FOR RELATOR
CERTIFICATE OF SERVICE
On the 2nd day of December, 2015, a true and correct copy of this
motion was transmitted to the Honorable Mollee Westfall, Judge of the
371st District Court of Tarrant County, Texas and Charles Reynolds,
Judicial Staff Counsel for Tarrant County, Texas.
/s/ Wes Ball_______________________________
WES BALL
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