NO. 13-15-00300-CR 

IN THE COURT OF APPEALS 

FOR THE THIRTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS 

AT CORPUS CHRISTI, TEXAS 

KRISTIN BOWLING, 

RELATOR 

vs.

HONORABLE JACK PULCHER, 

RESPONDENT 

SUPPLEMENTAL BRIEF AND MOTION TO STRIKE DISTRICT 

ATTORNEYS LAST FILING WITH THE COURT OF APPEALS

On Appeal from Cause Number 14-AC-0466 

in the 105th District Court of Kleberg County, Texas, 

Honorable Jack Pulcher, Judge Presiding 

ATTORNEYS FOR RELATOR 

DAVID T. GARCIA JAIME CARRILLO 

Attorney at Law CARRILLO LAW OFFICE, L.L.P.

721 E King Ave. 721 E. King Ave. 

Kingsville, Texas 78363 Kingsville, Texas 78363 

Ph.: (361) 595-4142 Ph.: (361) 595-4142 

Fax: (361) 595-0544 Fax: (361) 595-0544 

State Bar No. 07631800 State Bar No. 03879300 

davidtgarcia0881@gmail.com carrillolawoffice@sbcglobal.net

ACCEPTED

13-15-00300-CR

THIRTEENTH COURT OF APPEALS

CORPUS CHRISTI, TEXAS

8/5/2015 5:01:52 PM

CECILE FOY GSANGER

CLERK

 FILED IN 13th COURT OF APPEALS CORPUS CHRISTI/EDINBURG, TEXAS 8/5/2015 5:01:52 PM CECILE FOY GSANGER Clerk ------------------------ VOID AM ------------------------ RECEIVED IN 13th COURT OF APPEALS CORPUS CHRISTI/EDINBURG, TEXAS 8/5/2015 5:01:52 PM CECILE FOY GSANGER Clerk
TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES Attorney for Appellant, KRISTIN BOWLING and 

respectfully responds to the 13th Court of Appeals inquiry.

I.

On August 5, 2015, DAVID T. GARCIA received an inquiry from the 13th

Court of Appeal that they have received a notice from the Kleberg County District 

Attorney’s Office that the criminal case against KRISTIN BOWLING had been 

rejected. This attorney had not received written notice of that fact.

II.

KRISTIN BOWLING was released from the Kleberg County Jail for a 

warrant that was issued for violation of what appellant alleges were improper bond 

conditions issued by a court without jurisdiction.

III.

This attorney has made this argument that the District Court lacks jurisdiction 

to issue pre-trial orders in cases that have not been indicted in numerous previous 

cases to the Court calling to the attention of the Court and the District Attorney that 

the continuous standing requirement of pre-trial bond conditions in cases that have 

not been indicted are without jurisdiction. Numerous defendants have been arrested 

and incarcerated under this procedure. Every time an objection has been raised, the 

Court has either released the defendant at a later date or not accept the case.

IV.

If it is true that the District Attorney is rejecting this case, it only serves to 

verify and support our position that the District Court has no jurisdiction and no 

reason to have a standing pre-trial order.

V.

KRISTIN BOWLING was incarcerated for over 90 days despite having an 

evidentiary hearing of the lack of jurisdiction of the order. 
VI.

Appellant requests that the District Attorney’s filing of its Notice of Rejection 

be struck from the record since a copy of such was not sent to the Attorney of record 

nor was I notified of my client’s release from jail.

VII.

Without intervention by the Thirteenth Court of Appeals that the local District 

Court will continue to violate the Defendant’s constitutional rights with its standing 

order requiring pre-trial conditions on bonds or cases that have not been indicted. 

WHEREFORE PREMISES CONSIDERED appellant urges the Court to 

reject the notice filed by the District Clerk since it was not served on appellant’s 

attorney. Appellant seeks to continue with her writ of mandamus and requests for an 

order of prohibition.

Respectfully submitted,

DAVID T. GARCIA

ATTORNEY AT LAW

721 E. KING

KINGSVILLE, TX 78363

PH: (361) 595-4142

FAX: (361) 595-0544

 By: __________________________________

 DAVID T. GARCIA

 State Bar No. 07631800

 davidtgarcia0881@gmail.com

/s/David T. Garcia