NO. [*____*]
|
STATE OF TEXAS |
§ |
IN THE DISTRICT COURT |
| |
§ |
|
|
vs. |
§ |
[*____*] JUDICIAL DISTRICT |
| |
§ |
|
|
DEFENDANT |
§ |
COLLIN COUNTY, TEXAS |
APPLICATION FOR WRIT OF HABEAS CORPUS
SEEKING RELEASE BECAUSE OF DELAY UNDER ARTICLE 17.151
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes Defendant, defendant by and through his attorney of record, and makes this Application for Writ of Habeas Corpus Seeking Release Because of Delay Under Article 17.151.
I.
Defendant was arrested for the offense of Driving While Intoxicated, [*____*] offense on [*____*]. He has been continuously confined in the Collin County Adult Detention Center on this charge since that time, unable to post bond in the amount of $[*____*].
II.
Ninety days or more have passed since defendant's incarceration for the Felony offense of Driving While Intoxicated, during which time the state has not been ready for trial. Pursuant to Article 17.151 § 1(1), defendant must therefore be released on a personal bond, or by reducing the amount of bail required.
III.
Defendant respectfully requests this Court to grant defendant an evidentiary hearing and, after receiving evidence, to order a personal bond, or to reduce the amount of bail required sufficiently to cause his release.
WHEREFORE, PREMISES CONSIDERED, defendant prays that this Court grant and issue a Writ of Habeas Corpus to the Sheriff of Collin County, Texas, directing and commanding him to produce and have defendant before this court instanter, or at such time and place to be designated by this Court, then and there to show cause, if any he may have, why defendant should not be granted a personal bond, or given bail in an amount he can post conditioned that he be and appear at the said hearing and there await further orders of this Court.
Respectfully submitted,
By:
State Bar No. [*____*]
Attorney for Defendant, Defendant
CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing Application for Writ of Habeas Corpus Seeking Release Because of Delay Under Article 17.151 was hand delivered to the District Attorney's Office, at [*____*], on May 29, 2001.
Welcome to our Web site. We hope that you will find our site informative and useful. Our goal is to provide the highest quality legal services to you and your business in a timely fashion. We welcome the opportunity to talk with you and to discuss how we may be of service.
The Law Offices of Heather J. Barbieri pracitces criminal defense law in the following areas:
Virtually all Misdemeanor and Felony Criminal Defense charges
Drunk Driving and DUI Defense
Appeals
Writs of Habeas Corpus
Expunctions Proceedings
Federal Crimes
Domestic Violence
Drug Possession
Possession for Sales of Narcotics
Juvenile Crimes
Assault and Battery
Domestic Violence
Fraud
Robbery
Burglary
Grand Theft and Petty Theft
Embezzlement
Probation or Parole Matters
Sex Offenses
Lewd Conduct
Solicitation
Prostitution
Unlawful Conduct With a Minor
Molestation
Terrorist Threats
Reckless Driving
Driving on a Suspended License
DMV suspensions and hearings from Drunk Driving
All other Texas DUI and Criminal Defense matters everywhere in Texas.
The Law Offices of Heather J. Barbieri practices law in the areas throughout the Dallas/Ft. Worth Metroplex:
throughout the Dallas/Fort Worth Metroplex:
Collin County , including providing outstanding criminal defense law practice in the cities of:
Allen, Anna, Blue Ridge, Carrollton, Celina, Dallas, Fariview, Farmersville, Frisco, Garland, Josephine, Lavon, Lowry Crossing, Lewis, McKinney, Melissa, Murphy, Nevada, New Hope, Parker, Plano, Princeton, Prosper, Richardson, Royse City, Sachse, Saint Paul, Van Alstyne, Weston, Wylie
Dallas County , including providing outstanding criminal defense law practice in the cities of:
Addison, Balch Springs, Buckingham, Carrollton, Cedar Hill, Cockrell Hill, Coppell, Dallas, DeSoto, Duncanville, Farmers Branch, Flower Mound, Garland, Glenn Heights, Grand Prairie, Highland Park, Hutchins, Irving, Lancaster, Lewsville, Mesquite, Ovilla, Richardson, Rowlett, Sachse, Seagoville, Sunnyvale, University Park, Wilmer, Wylie
Denton County , including providing outstanding criminal defense law practice in the cities of:
Argyle, Aubrey, Bartonville, Carrollton, Coppell, Copper Canyon, Corinth, Corral City, Cross Raods, Dallas, Denton, Double Oak, Flower Mount, Forth Worth, Frisco, Grapevine, Hackberry, Hasley, Hebron, Hickory Creek, Highland Village, Jusin, Krugerville, Krum, Lake Dallas, Lakewook Village, Lewisville, Lincoln Park, Little Elm, Marshall Creek, Northlake, Oak Point, Pilot Point, Plano, Ponder, Roanoke, Sanger, Shady Shores, Southlake, The Colony, Trophy Club, Westlake
Welcome to our Web site. We hope that you will find our site informative and useful. Our goal is to provide the highest quality legal services to you and your business in a timely fashion. We welcome the opportunity to talk with you and to discuss how we may be of service.
The Law Offices of Heather J. Barbieri pracitces criminal defense law in the following areas:
Virtually all Misdemeanor and Felony Criminal Defense charges
Drunk Driving and DUI Defense
Appeals
Writs of Habeas Corpus
Expunctions Proceedings
Federal Crimes
Domestic Violence
Drug Possession
Possession for Sales of Narcotics
Juvenile Crimes
Assault and Battery
Domestic Violence
Fraud
Robbery
Burglary
Grand Theft and Petty Theft
Embezzlement
Probation or Parole Matters
Sex Offenses
Lewd Conduct
Solicitation
Prostitution
Unlawful Conduct With a Minor
Molestation
Terrorist Threats
Reckless Driving
Driving on a Suspended License
DMV suspensions and hearings from Drunk Driving
All other Texas DUI and Criminal Defense matters everywhere in Texas.
The Law Offices of Heather J. Barbieri practices law in the areas throughout the Dallas/Ft. Worth Metroplex:
throughout the Dallas/Fort Worth Metroplex:
Collin County , including providing outstanding criminal defense law practice in the cities of:
Allen, Anna, Blue Ridge, Carrollton, Celina, Dallas, Fariview, Farmersville, Frisco, Garland, Josephine, Lavon, Lowry Crossing, Lewis, McKinney, Melissa, Murphy, Nevada, New Hope, Parker, Plano, Princeton, Prosper, Richardson, Royse City, Sachse, Saint Paul, Van Alstyne, Weston, Wylie
Dallas County , including providing outstanding criminal defense law practice in the cities of:
Addison, Balch Springs, Buckingham, Carrollton, Cedar Hill, Cockrell Hill, Coppell, Dallas, DeSoto, Duncanville, Farmers Branch, Flower Mound, Garland, Glenn Heights, Grand Prairie, Highland Park, Hutchins, Irving, Lancaster, Lewsville, Mesquite, Ovilla, Richardson, Rowlett, Sachse, Seagoville, Sunnyvale, University Park, Wilmer, Wylie
Denton County , including providing outstanding criminal defense law practice in the cities of:
Argyle, Aubrey, Bartonville, Carrollton, Coppell, Copper Canyon, Corinth, Corral City, Cross Raods, Dallas, Denton, Double Oak, Flower Mount, Forth Worth, Frisco, Grapevine, Hackberry, Hasley, Hebron, Hickory Creek, Highland Village, Jusin, Krugerville, Krum, Lake Dallas, Lakewook Village, Lewisville, Lincoln Park, Little Elm, Marshall Creek, Northlake, Oak Point, Pilot Point, Plano, Ponder, Roanoke, Sanger, Shady Shores, Southlake, The Colony, Trophy Club, Westlake
