Heather J. Barbieri, P.C.

APPLICATION FOR WRIT OF HABEAS CORPUS SEEKING BAIL REDUCTION

NO. [*____*]

STATE OF TEXAS

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IN THE DISTRICT COURT

 

§

 

vs.

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[*____*] JUDICIAL DISTRICT

 

§

 

DEFENDANT

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COLLIN COUNTY, TEXAS

 

APPLICATION FOR WRIT OF HABEAS CORPUS SEEKING BAIL REDUCTION

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 Bail Reduction, and for good cause shows the following:

I.

Defendant is illegally confined and restrained of his liberty by the Sheriff of Collin County, Texas in the Collin County Adult Detention Center in [*____*], Texas in lieu of a bond in the amount of $[*____*]. Defendant is charged with Driving While Intoxicated, [*____*] offense.

II.

Defendant's confinement and restraint is illegal because his bond is excessive, oppressive and beyond his financial means, in violation of the Eighth and Fourteenth Amendments to the United States Constitution, Article I, §§ 11, 13 and 19 of the Texas Constitution, and Articles 1.07 and 17.15 of the Texas Code of Criminal Procedure.

III.

Defendant respectfully requests this Court to grant defendant an evidentiary hearing and, after receiving evidence, to reduce the amount of said bond to a reasonable amount in order that defendant will have an opportunity to obtain his release from incarceration pending trial.

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 discharged from such illegal confinement; or that defendant be allowed bail in a reasonable amount; and defendant further prays that he be allowed immediate bail in a reasonable amount, conditioned that he be and appear at the said hearing to 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 Bail Reduction 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

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