~ -.. RECEIVED IN 

COURT OF CRIMINAL APPEALS 

CauseNO. 20/~ Lf{ hDOOI/-

DEC 08 2015 

THE STATE OF TEXAS 

Abel ~Gosta, Clerk '· 

f}{q_ 1 t< ()u f <(!__5;. 

IN THE DISTRICT COURT 

?z.J.1_ JUDICIAL DISTRICT 

BEXAR COUNTY, TEXAS 

PETITION FOR WRIT OF HABEAS CORPUS 

RELEASE BECAUSE OF DELAY 

To·Cour/f o~··C(;lmfn~l tllf'~&-

come now, f!JCtt/ {< {)?< /c::; <2$ · Petitioner in the above styled and 

numbered cause and files his Petition for Release Because of Delay and in support of said 

petition would show the Court the following: 

I. 

Petitioner is illegally confined in Bexar County Adult Detention Center,- in the custody 

of ~UG C!(/1 {J4 t!Aif/rpq(J , Sheriff of Bexar County, Texas, and has 

been so confined since the date of his arrest on the / 'IJ" day of 

II. 

~ ~··· •, 

_ Petitioner is confined pursuant to criminal complaint number 26,&-(£CtJCJtJflfiled in the S £7 Judicial District Court of Bexar Cminzy, Texas, charging Petitioner 

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with the felony offense ofr;&.J f.J...~t=/1_~ £ /) l1t/(fJ a violation of Section 3 2_. S 

I 

of the Texas Penal/Health & Safety Code. 

III. 

Bond has been set in the amount of$ /Dr aJj . Petitioner has not been 

authorized to be released on personal bo~d lnd has been unable to post a surety bond in the · 

amount set. 
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IV. 

More than ninety (90) days have elapsed since the commencement of this criminal 

action against Petitioner and pursuant to Section 17.151 of the Texas Code of Criminal 

Procedure, Petitioner should be released from incarceration. Section 17.151 states in part, 

"A defendant who is detained in jail pending trial of an accusation against him must be 

released either on personal bond or by reducing the amount of bail required, if the state is 

not ready for trial of the criminal action for which he is being detained within: 

(1) 90 days from the commencement of his detention if he is accused of a felony." 

Therefore, no statutory grounds exist to prevent the release of Petitioner because of 

delay of trial. 

WHEREFORE, PREMISES CONSIDERED, Defendant prays a Writ of Habeas Corpus 

issue and have Petitioner brought before this Court instanter, to the end that he be released 

from confinement upon posting a personal bond, or that the amount of bond heretofore set 

be reduced to $ S 60 , which is an amount Petitioner can make. 

Respectfully submitted, 

Attorney for Petitioner Petitioner 

CERTIFICATE OF SERVICE 

I, hereby certify that on this the 1Q day of l/0 u<:lll}tet', 20/~ A true and 

correct copy of the above and foregoing Petition for Writ ofHabeas Corpus Because of 

Delay was transmitted to the office of the Bexar County District Attorney, Criminal Justice 

Center, 101 W. Nueva, San Antonio, Texas 78205 

Petitioner 
ACKNOWLEDGEMENT 

STATE OF TEXAS * * * * * 

COUNTY OF BEXAR * * * * * 

B,efore me, th{)_e undersigned authority, on this ~~y per~onally appeared . 

/llJ9r;i ~uK0 , PetitiOner m the above and foregomg 

Petition for Writ of Habeas Corpus Release Because of Delay, who after being duly sworn 

stated that the facts contained therein are true and correct. 

Sworn to and signed on this the . 3D day of !llo 1-P m ~ 

otary Pubhc