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### -.. RECEIVED IN COURT OF CRIMINAL APPEALS CauseNO.

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# Lf{ hDOOI/- DEC 08 

## 2015
THE STATE OF TEXAS 

### Abel**~Gosta,** 

### Clerk '· 

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# f <(!__5;. IN THE DISTRICT COURT 

# ?z.J.1_ JUDICIAL DISTRICT

BEXAR COUNTY, TEXAS

PETITION FOR WRIT OF HABEAS CORPUS RELEASE BECAUSE OF DELAY 

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# {)?< /c::; <2$ · Petitioner in the above styled and numbered cause and files his Petition for Release Because ofDelay 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

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## {J4 t!Aif/rpq(J , SheriffofBexar County, Texas, and has been so confined since the date ofhis arrest on the / 

# 'IJ" day of



### II.**~ ~···**  •,

_ Petitioner is confined pursuant to criminal complaint number 

# 26,&- (£CtJCJtJflfiled in the

# S£7 Judicial District Court ofBexar Cminzy, Texas, charging Petitioner 

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# 1 with the felony offense 

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## l1t/(fJ a violation of Section 

# 3 2_.

# S I ofthe Texas Penal/Health & Safety Code. 

### III. Bond has been set in the amount of$

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. 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.**(~**
IV. More than ninety (90) days have elapsed since the commencement ofthis criminal action against Petitioner and pursuant to Section 17.151 ofthe Texas Code of Criminal Procedure, Petitioner should be released from incarceration. Section 17.151 states in part, "A defendant who is detained injail pending trial ofan accusation against him must be released either on personal bond or by reducing the amount ofbail required, ifthe state is not ready for trial ofthe criminal action for which he is being detained within: (1) 90 days from the commencement ofhis detention ifhe is accused ofa felony." Therefore, no statutory grounds exist to prevent the release ofPetitioner because of delay oftrial. WHEREFORE, PREMISES CONSIDERED, Defendant prays a Writ ofHabeas 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 ofbond 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 ofthe above and foregoing Petition for Writ ofHabeas Corpus Because of Delay was transmitted to the office ofthe Bexar County District Attorney, Criminal Justice Center, 101 W. Nueva, San Antonio, Texas 78205

PetitionerACKNOWLEDGEMENT

STATE OF TEXAS 

## * * * * * COUNTY OF BEXAR 

## * * 

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

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# ,PetitiOner m the above and foregomg Petition for Writ ofHabeas Corpus Release Because ofDelay, 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 

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