Abel Acosta · 

Abel Medrano 11743611 

Dalhart Unit TDCJ 

1 1 9 5 o I? r•J 9 9 a 

Dalhart, Texas 79022 

April 03, 2015 

Clerk, Criminal Appeals 

P.o. Box 12308, Capitol Station 

Austin, Texas 78711 · 

RE: State of Texas v Abel Medrano, ~8602 

Sub: Motion to Stay Proceedings with Order 

Dear Clerk: 

MOTION DJCNI~ID 

DATE: LM:30-f5 

BY: PG 

Enclosed please find for filing Movant's Motion to Stay Proceedings with Orde~. Please file date stamp and bring to the attention of the Court. 

Also e~cilosed, ·please find a ~dpy of this letterhead. Please file 

date s famr> same and return in the provided se l f.i addressed starnped 

envolp~e~~:·~··?·- · .. : · ·:.·\\ /::.IJ. •. ~~ .·~ .· t~ ,·· 

··~ :t ~.. ,_:~ _:· . ·. ·s. ~-; . -J \, ; , _. ~- >~ >i·:. 

Th~nkl you for your assistance on this matter. 

·sincerely, 

-~------···· 

~-------- Abel Nedrano 

t'lovan t pro se 

RECEIVED IN 

COURT OF CRIMINAL APPEALS 

APR 15 2015 

_J\bei_Ac,osta, Clerk 

AM/ 

.. cc: .- 'i:r'Lf' :· · .. '·. . ', I' . ' .··-.. 

.' ~· . •. 

Larry Allison, P.O. Box 1300, Lampasas, Texas 76550, Via u.s. ··Po~tal Secvice, first class, postage prepaid. 

Enclo·sure: Origl.:nal· Motion to Stay' ·Proceedin<_is wlth Order; self 

.addressed stamped .envelppe 
EX PARTE 

ABEL MEDRANO 

NO. ----------------------- IN THE 

COURT OF CRIMINAL APPEALS 

AUSTIN, TEXAS 

§ 

§ 

§ 

ORIGINATING IN THE 27th 

DISTRICT COURT IN AND FOR 

LAMPSAS COUNTY, TEXAS 

MOTION TO STAY PROCEEDINGS 

TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS: 

COMES NOW, Abel Medrano, Texas Department of Criminal justice ;zy, 

(TDCJ)-ID #1743611, hereinafter "Movant" pro se in the above captioned cause and moves this Honorable Court to Stay Proceedings, 

not for reason of delay but, requesting due process and offers 

this Honorable Court the following in support thereof: 

Statement of the Case 

On January 28, 2015, Movant filed Original Application for ~vrit 

of Habeas Corpus, §11.07, §11.073, with the district clerk of Lampasas, Texas, Lampasas County, with Memorandum in Support. 

On March 11, 2015, Movant's application was received by this 

Court's Honorable Clerk and present to the Court. 

On March 24, 2015, Movant received the Clerk's notice of same. 

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On March 30, 2015, Movant sent correspondence to the district 

clerk requesting a copy of the State~s Answer be forwarded immediately. 

To date, Movant has not received a copy of the requested, nno 

has he received notice that the State filed an answer in response 

to his application. 

Due Process 

Movant is r~questing he be afforded due process guaranteed to 

him by the Fourteenth Amendment to the United States Constitution 

and Ar.ticle 1, subsections 10 and 19, on the Texas Constitution, 

in the event the State has in fact filed an answer in response to 

his application, .but has failed to inform and forward a copy_of 

same, in violation of due process. 

Conclusion 

Movant requests an opportunity to file an objection and refute 

any and all assertions and/or contentions made by the State_and 

contained in their answer in response to his application for Writ 

of Habeas Corpus, §11.07, §11.073. Movant requests t~~t the State 

be compelled to forward Movant a copy of same, if one in fact has 

been filed with his application in this Court. Movant is entitled 

to due process in this proceeding and requests an opportunity_to 

file an objection, refuting any and all assertions and/or contentions wit&'n the State's answer. Movant requests that the time 

frame to be reinstated to reflect the proper time to begin the 

date Movant receives the requested copy of the State's answer. In 

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the event the State has failed to file an answer pursuant to_the 

Texas Code of Criminal Procedure(CCP) art. §11.07(3)(a), only 

filing Movant's application by itself, Movant requests this_Honorable Court to consider this Motion to Stay Proceedings, as moot 

and to grant his application for Writ of Habeas Corpus, §11.07, 

§11.073. 

Prayer 

WHEREFORE, PREMISES CONSIDERED, Movant respectfully requests 

this Honorable Court to consider Movant's Motion to Stay Proceed-. 

ings and to issue an Order this Honorable Court deems appropriate 

in this cause. So prayed • 

. l 

Respectfully submitted, 

~ __.-· 

Abel Medrano #1743611 . 

Dalhart Unit TDCJ 

11950 FM 998 

Dalhart, Texas 79022 

Movant poo se 

Certificate of Service 

I, Abel Medrano, hereby certify that a true and correct_copy 

of the foregoing Motion to Stay Proceedings was filed on this the 

3rd day of April, 2015, by placing same in the Dalhart Unit's internal mail system addressed to: Larry Allison, P.O. Box 1300, 

Lampasas, Texas 76550: and to the Honorable Clerk of the Court of 

Criminal Appeals, P.O. Box 12308, Capitol Station, Austin, Texas 

78711. 

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Movant pro se 

Unsworn 6eclaration 

I, Abel Medrano, TDCJ-ID #1743611, being presently incarcerated in the Dalhart Unit of the Texas Departmwen' of Criminal 

Justice in Hartley County, Texas, verify and declare under penalty of perjury, that the foregoing statements are true and correct 

and that the original Motion to Stay Proceedings were placed_in 

the Dalhart Unit's internal mailing system on this the 3rd day of 

April, 2015. 

Executed on this the 3rd day of April, 2015. 

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~-------·· 

Abel Medrano #1743611 

Movant pro se 
<I ' • ' 

EX PARTE 

ABEL MEDRANO 

NO. --------------------- IN THE 

COURT OF CRIMINAL APPEALS 

AUSTIN, TEXAS 

§ 

§ 

§ 

,.. ORDER 

ORIGINATING IN THE 27th 

DISTRICT COURT IN AND FOR 

LAMPASAS COUNTY, TEXAS 

On this, the day of , 2015, came to be ---------- ------------------~ 

heard the Movant's Motion to Stay Proceedings and after having 

reviewed the pleadings, heard the evidence, ~and the argument of • .. ·,·· ' . . ' • I :'""~'1.;""·•~!1· - • 

Counsel, this Court is of the opinion that said Motion to Stay 

Proceedings should be: [ ]GRANTED [ ]DENIED AS MOOT 

IT IS THEREFORE ORDERED that the Movant's Motion to Stay Proceedin~s is GRANTED / DENIED AS MOOT, and IT IS FURTHER ORDERED 

that the Clerk of the Court issue same to all parties. 

SIGNED ON THIS DAY, THE ____ DAY OF ___________ ___:, 2015 • 

.. . 

;~· JUDGE PRESIDIN"C; . '•: 

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