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 105 th 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

CLERKTO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES Attorney for Appellant, KRISTIN BOWLING and respectfully responds to the 13 th Court of Appeals inquiry.

I.

On August 5, 2015, DAVID T. GARCIA received an inquiry from the 13 th
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 rele ased 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 jurisdict ion 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 h ave 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 9 0 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