. -., ' ' ' 

No. _____ _ 

IN THE STATE OF TEXAS COURT 

OF CRIMINAL APPEALS ON 

ORIGINAL ACTION JURISDICTION 

APPLICANT'S PRO SE MOTION SEEKING COURT LEAVE TO 

FILE ORIGINAL ACTION APPLICATION FOR 

WRIT OF HABEAS CORPUS This document contains som€ 

pages that are of poor quality 

To the HONORABLE CLERK of said COURT: at the time of imaging. 

Comes now IRSHAD ISMAIL BAIG, pro se Applicant in cause sub judice and 

submits his pro-se MOTION SEEKING COURT LEAVE TO FILE ORIGINAL ACTION 

APPLICATION FOR WRIT OF HABEAS CORPUS. 

I. 

JURISDICTIONAL STATEMENT 

RECEIVED IN 

COURT OF CRI~RINAL APPEALS 

SEP 14 2015 

Abet Acosta, Clerk 

(1) Applicant IRSHAD ISMAIL BAIG is being restrained ofhis constitutional protected 

liberty and property interest by virtue of Fort Bend County Cause Number 15-CCR180026 under color of STATE OF TEXAS statutory law contrary to and inconsistent 

with the official Constitution(s) of Texas and United States of America. Texas Code 

of Criminal Procedure (2012) Articles 11.01, 11.04, 11.05, 11.09. 

II. 

STATEMENT OF CASE 

(2) Applicant was initially charged by Information under Article 22.01 (a) (1) Texas 

Code of Criminal Procedure (See Attachment A- Fort Bend County Register of 

Actions) on or about Aprill3, 2015. 

Page 1 of 3 
'· ··., ' -· 

.. 

(3) On or about May 13, 2015 Applicant filed his pro-se Application For Writ of Habeas 

Corpus, Article 11.09 Tex. Code Crim. Proc. (2012). See Attachment A. 

(4) In the United States Supreme Court Case ofLaChance V. Erickson 522 U.S. 262, 

266; 118 S. ct. 753 (1998) and progeny it was plainly established "IF A LIBERTY 

INTEREST IS CREATED BY STATUTE, DUE PROCESS REQUIRES NOTICE 

AND MEANINGFUL OPPORTUNITY TO BE HEARD." Furthermore, in TARTER 

V. HURY 646 F. 2d 1010 (51h Cir. 1981) and progeny this Circuit plainly established 

"Pro se litigant entitled to have pro-se motions considered by court although he had 

appointed counsel". 

(5) Applicant IRSHAD ISMAIL BAIG, while proceeding pro-se during prosecution of 

·Cause Number 15-CCR-180026, made numerous documented attempts to have the 

Fort Bend County Court #3 entertain his pro-se Art. 11.09 Habeas Corpus 

Application, however, said trial court has to date ignored every single pleading 

Applicant had properly filed. During over 100 days of documented prosecution of 

said Cause (supra) the trial court has set and reset said Cause for jury trial. Clearly, 

taking the case to jury trial would blatantly moot and thus deny Applicant's State of 

Texas and United States Constitutional Right/Entitlement to have his Art. 11.09 

Application entertained, addressed by the trial court. 

(6) On or about September 10,2015 Applicant filed his pro-se motion to "WITHDRAW 

SUBJECT MATTER JURISDICTION IN ORDER TO PROCEED ORIGINAL 

ACTION JURISDICTION OF TEXAS COURT OF CRIMINAL APPEALS." See 

Attachment B [3 Motions]. 

Page 2 of 3 
PREMISES CONSIDERED: 

(7) Applicant prays the Court to GRANT LEAVE TO FILE ORIGINAL ACTION 

ARTICLE 11.09 Application For Writ OF HABEAS CORPUS attached hereto and 

thereafter GRANT/ISSUE THE WRIT sua sponte; in all things. So Moved and 

Prayed. 

Sworn to and Subscribed 

before me hI J.J .M · /J1 Etfl'ZA 

this/J..~y ofSeptember 2015 

N!:::~ Fort Bend County, Texas 

AMIN M MEERZA 

My Commission Expires · J 

June1.2016 ~ 

;'"_vy(.,.. 

\ ' ' \ 

i 

IRSHAD ISMAIL BAIG 

11706 Nobility Drive, Stafford, TX 77477 

Page 3 of 3 
( 

\ 

. 9/11.'2015" tyler paw .co.fort-bend.tx.us/CaseDetail.aspx?CaseiD= 1464206 . ~ 

State of Texas vs lrshad Ismail Baig 

Related Cases 

14-CCR-177950 (Other) 

Defendant Baig,lrshad Ismail 

Stafford, TX 77477 

State State of Texas 

Witness 

Witness 

Witness 

Richmond, TX 77469 

Baig, Kausar Jehan 

Meadows Place, TX 77477 

Davis, Kelly 

Meadows Place, TX 77477 

Muratee, Shobana 

SUGAR LAND, TX 77478 

Charges: Baig,lrshad Ismail 

1. ASSAULT CAUSES BODILY INJURY FAMILY VIOLENCE 

04/13/2015 

04/13/2015 

04/13/2015 

04/13/2015 

04/13/2015 

04/13/2015 

04/20/2015 

04/20/2015 

OTHER EVENTS AND HEARINGS 

Complaint 

Information 

Docket Sheet 

Case Filed (open event)- Criminal 

AJ;!plication/Reguest for Summons 

by State 

Warrant Information Sheet 

Summons - Mail 

lrshad Ismail Baig 

Summons 

Baig, lrshad Ismail 

Motion !No Feel 

REGISTER OF ACTIONS 

CASE No. 15-CCR-180026 

§ 

§ 

§ 

§ 

§ 

RELATED CASE INFORMATION 

pARTY INFOR:\IATION 

Male Asian 

5' 8", 190 lbs 

Female Asian 

Female Asian 

CHARGE INFORMATION 

Statute 

22.01 (a)(1) 

Evr.:ws & ORDERS OF THE CouRT 

Unserved 

Case Type: Adult Misdemeanor- Filed by Information 

Date Filed: 04/13/2015 

Location: County Court at Law 3 

Attorneys 

Level Date 

Class A Misdemeanor 11/09/2014 

05/01/2015 

05/01/2015 

05/13/2015 

05/13/2015 

Defendant Pro Se Motion for Self Repr esentation at Jury Trial and All Related Court Process in Above Styled, Numbered Cause of Action 

05/22/2015 

06/26/2015 

06/26/2015 

06/26/2015 

06/30/2015 

06/30/2015 

06/30/2015 

06/30/2015 

07/14/2015 

07/14/2015 

Affidavit 

of Nolle Prosequi 

Writ of Habeas CorJ;!US Pre-Judgment 

Motion (No Feel 

to quash charging complaint; dismiss pr osecution 

Reset 

Notice 

Certificate of Service 

Motion !No Feel 

Defendant Po Se Motion Requesting C ourt to Order its Clerk/Reporter to Make Complete Transcription 

Motion !No Feel 

for Court to set date on docket for Moti ons hearing 

Reset 

Reset 

Motion !No Feel 

Pro Se Motion to Hold All Proceedings i n Abeyance 

Jury 

CoJ;!y Reguest 

Motion for Discoverv 

and order 

http://tylerpaw .co.fort-bend.tx.us/CaseDetail.aspx?CaseiD= 1464206 1/2 
9/11/2015 

. ___..: . \,..:"' 

07/14/2015 

07/14/2015 

07/20/2015 

. 07/20/2015 

07/21/2015 

07/21/2015 

07/28/2015 

08/18/2015 

08/18/2015 

08/18/2015 

08/18/2015 

08/24/2015 

08/24/2015 

08/24/2015 

08/24/2015 

09/04/2015 

09/15/2015 

tylerpaw.co.fort-bend.tx.us/CaseDetail.aspx?CaseiD=1464206 

Motion (No Fee} 

requesting finding offact w ith conclusions of law/ and order 

Motion (No Fee} 

objection to trial court cons olidation of more than one charging instrument offense for prosecution in a single triaV and order 

Motion (No Fee) 

Def Pro-Se Motion Electin g Trial Jury to Assess Punishment 

Motion (No Fee} 

Reset 

Motion (No Fee} 

To Dismiss Cause Sub Ju dice For Want of Prosecution (Pro Se) 

A!;!!;!lication for Sub1;1oena 

Subeoena- Constable 2 

Kausar Jehan Baig 

Subeoena- Constable 2 

Kausar Jehan Baig (Duce s Tecum) 

Subeoena - Constable 2 

Kelly Davis 

Subeoena- Constable 4 

Shobana Muratee 

Subpoena 

Baig, Kausar Jehan Unserved 

Subpoena 

Baig, Kausar Jehan Unserved 

Subpoena 

Davis, Kelly Unserved 

Subpoena 

Muratee, Shobana Returned Unserved 09/03/2015 

Returned 09/03/2015 

Motion (No Fee} 

Applicant Pro Se Motion T 

Jury Trial (11 :00 AM)(Judi 

o Expedite Disposition of Subject Matter In Article 11.09 Application For Haveas Corpus Relief 

cial Officer Lowery, Susan G.) 

ProSe 

0512212015 Reset by Co 

06/3012015 Reset by Co 

0712112015 Reset by Co 

urt to 0613012015 

urt to 07121/2015 

urt to 0911512015 

http://tylerpaw .co.fort-bend.tx.us/CaseDetail.aspx?CaseiD= 1464206 2/2 
,.-' 

STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No. 15-CCR -180026 

County Court at Law No. 3 

Fort Bend County, Texas 

) 

) IN THE COUNTY COURT AT LAW 

) NO.3 

) 

) FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) _______________________________ ) 

IN THE COURT OF CRIMINAL APPEALS OF TEXAS 

APPLICATION FOR WRIT OF HABEAS CORPUS 

(T.C.C.P. ARTICLE 11.09; 11.05; 11.04; 11.01) 

Applicant: IRSHAD ISMAIL BAIG 

Date of Birth: April 07, 1964 

STATEMENT OF CASE 

1) On or about November 18, 2014, Kausar Baig, wife of Applicant herein, 

made a criminal Complaint with Meadows Police Department of Fort Bend 

County, Texas implying family violence may have occurred. 

2) A judicial Protection Order was applied for by C.P.S. (Child Protection 

Service) and was summarily granted, temporarily prohibiting Applicant from 

associating with or contacting his immediate family in Cause number 14-DCV219, 272 on or about December 01, 2014. Earlier, on or about November 9th thru 

14th, 2014, after C.P.S. officers had interviewed my wife, she was threatened in the 

Page 1 of6 
.. .· .. 

No. 15-CCR -180026 

14 BCR 968919 

County Court at Law No.3 

Fort Bend County, Texas 

) 

15-CCR-180026 

WRHCF 

Writ ol Habeas Corpus Pre-Judgment 

. ii\l\11\ll\\l\11\ Ill 

STATE OF TEXAS ) IN THE COUNTY COURT AT LAW 

) NO.3 

v. ) 

) FOR 

IRSHAD ISMAIL BAIG, ) 

Defendant, Pro Se 

) 

) FORT BEND COUNTY, TEXAS 

) 

IN THE COURT OF CRIMINAL APPEALS OF TEXAS 

APPLICATION FOR WRIT OF HABEAS CORPUS 

(T.C.C.P. ARTICLE 11.09; 11.04) 

Applicant: IRSHAD ISMAIL BAIG 

Date of Birth: April. 1964 

STATEMENT OF CASE 

1) On or about November 18, 2014, Kausar Baig, wife of Applicant herein, 

made a criminal Complaint with Meadows Police Department of Fort Bend 

County, Texas implying family violence may have occurred. 

2) A judicial Protection Order was applied for by C.P.S. (Child Protection 

Service) and was summarily granted, temporarily prohibiting Applicant from 

associating with or contacting his immediate family in Cause number 14-DCV219,272 on or about December 01,2014. Earlier, on or about November gth thru 

14th, 2014, after C.P.S. officers had interviewed my wife, she was threatened in the 

Page 1 of6 
following manner "If you do not sign an Affidavit against your husband, today we 

will take official custody against your three children and put them in a State 

Home." 

3) After the Protective Order was granted, the state of Texas as well as the 

County of Fort Bend, Texas elected to file and prosecute subsequent felony and 

misdemeanor charges against Applicant under Cause Numbers 14-DCR-68010 

(felony) and under 14-CCR-177950, December 2014, January 2015. 

4) On or about January 26,2015, the state ofTexas moved to Dismiss the 

protective Order and Court granted same. See: Attachment 1. 

5) On or about April 13, 2015, the state of Texas moved to Dismiss felony 

prosecution in Cause Number 14-DCR-68010 to re~file same as Misdemeanor in 

Cause Number 15-CCR-180026, subjudice. 

6) Applicant is now before the Court seeking habeas corpus relief from what he 

perceives to be unwarranted judicial harassment and blatant abuse of tax payer 

funds. 

LEGAL CLAIM 

7) Applicant is presently restrained of his liberty and property interests in Fort 

Bend County, Texas under color of State of Texas law in manner contrary to and 

inconsistent with the Constitution and law of the United States of America and 

specifically the FOURTH, FIFTH, SIXTH, and FOURTEENTH Amendments 

Page 2 of6 
' . 

thereto. 

8) Applicant herein urges the writ of Habeas Corpus to issue forth against Fort 

Bend County Misdemeanor Complaint/Information number 15-CCR-180026 and 

Dismiss with Prejudice all charges incident thereto. 

CAUSE 

9) Applicant is a resident of Fort Bend County living at 11706 Nobility Drive, 

Stafford, Texas, 77477 thus in personam jurisdiction is satisfied. Jurisdictional 

authority is under T.C.C.P. Article 11.09 (2010); Article 11.04 (2013). 

1 0) By virtue of criminal Complaint/Information in Cause number 15-CCR180026 in Fort Bend County, Texas there has arisen applicable Bail Bond restraints 

as well as numerous and continuing open court appearances which mandate lost 

working days (Applicant recently laid off after 17 years because of taking too 

much time off for courts). All of paragraph 10 restraints conclusively establish 

injury to both Applicant's liberty interests and vested property rights which are 

severely injured. U.S. Supreme Court declares money as property and 19¢ injury 

states valid Claim. 

11) Applicant complained of liberty restraint has been in effect since on or about 

December 15, 2014 some 130 days of restraint with continuing effect has elapsed, 

regardless of fact Applicant admonished the diverse judges, D.A., trial courts that 

Applicant desired a fast and speedy trial on merits. Applicant has not yet been to 

Page 3 of6 
trial and the State Prosecutors have NO valid evidence to set before a jury beyond 

that of mere speculation which cannot sustain a conviction. BARKER V. WINGO 

_ S. Ct._ (1972); WEBBER V. STATE, 29 S.W. 3d 226 (P.D.R. ref.) Tex. App. 

Hou. (14th) 2000; T.C.C.P. Art. 38.03 and progeny. 

12) Finally, Applicant's constitutional rights are essentially a federal question 

and the instant Pleading is filed to exhaust state remedy at this point. 

13) Applicant is supporting his legal claims herein with copy( s) of authentic 

evidence via sworn, notarized Affidavit( s) and relevant Fort Bend County 

documents. 

14) Applicant has submitted herewith at Attachment A, B: State MOTION TO 

DISMISS PROSECUTION in Fort Bend County, 434th Judicial District, Cause 

Number 14-DCR-68010 and State INFORMATION in Cause Number 15-CCR180026. 

15) Applicant has submitted herewith as EXHIBITS 2, 3, 4 the sworn, notarized 

Affidavits of KAUSAR IRSHAD BAIG, at #2; ZAID IRSHAD BAIG , at #3; 

IRSHAD ISMAIL BAIG, at #4 

16) At paragraphs 3, 4, 5 ofKAUSAR's Affidavit there exists material facts of 

fear that has coercion implications; irrebuttable declarations which is clearly 

negative of State criminal statutes required mens rea criteria. 

17) At paragraphs 3, 4, 5 of ZAID's Affidavit there exists material facts, 

Page 4 of6 
negative of State criminal statutes required mens rea criteria. 

18) At paragraphs 4, 5, 6 ofiRSHAD's Affidavit there exists material fact 

declaring negative impact upon State criminal statutes and specifically those 

relating to a person's actions or omissions under severe duress as established by 

sworn Affidavit ofKAUSAR IRSHAD BAIG, Exhibit 2 herewith. 

19) A cursory review of all State evidence in this case even including its 

companion cases should reveal the State's entire prosecution of Applicant here has 

evolved from a woman under duress seeking only some kind of temporary 

protective order at suggestion of a neighbor/friend when neither ever realized the 

State (local) prosecutors could or would take more extreme action against her 

entire family. Regardless, however, the status quo of the present State position is 

frivolous at best. Please take note also of the Sworn Affidavits of Nolle Prosequi 

on file with Fort Bend County Court and Prosecutors attached herewith, at 

Attachments Aland A2. 

PREMISES CONSIDERED: 

20) Applicant respectfully moves the honorable Court to DISMISS with/without 

Prejudice the State Information in Misdemeanor Cause number 15-CCR-180026. 

So Moved and Prayed 

(\ . , 

)v7" 

IRSHAD ISMAIL BAIG 

Page 5 of6 
ORDER 

On the _ day of , 20 15 came on to be heard the Application for 

WRIT OF HABEAS CORPUS under Texas Code Criminal Procedure, Article 

11.09 (2014) and having given due consideration to same, including the evidence 

submitted therewith, the Court is of the opinion the WRIT be 

GRANTED/DENIED and on this same day the State Information is 

DISMISSED/ ALLOWED to proceed. 

Date: , 2015 -------

Presiding Judge 

Page 6 of6 
STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No. 15-CCR-180026 

County Court at Law No.3 

Fort Bend County, Texas 

) 

) IN THE COUNTY COURT AT LAW 

) NO.3 

) 

) FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

CERTIFICATE OF AUTHENTICITY 

I, IRSHAD ISMAIL BAIG, Habeas Corpus Applicant in above styled, 

numbered Cause of Action, hereby, herein swear upon oath under penalty of 

perjury according to law that all EXIDBITS and ATTACHMENTS evidentiary in 

scope, nature included with instant Certificate are true and correct photo copies of 

the Original documents on file with Fort Bend County and District Clerk Offices in 

Fort Bend County, Texas. 

IRSHAD ISMAIL BAIG 

Notary Public, in and for 

Fort Bend County, Texas 
IN THE MATTER OF 

KAUSAR BA·IG 

APPLICANT 

AND 

IRSHAD BAIG 

RESPONDENT 

. AND ON BEHALF OF 

NO. 14-DCV-219,272 

§ IN THE 328th DISTRICT COURT 

§ OF 

§ FORT BEND COUNTY, TEXAS 

ZAID BAIG, AMAN BAIG, KABIR BAIG 

MOTION TO DISMISS 

COMES NOW, Tonika Davis, Assistant District Attorney of For~ 

Bend County, Texas, on behalf of Applicant and respectfully 

requests this Court to Dismiss Without Prejudice, the above 

entitled and numbered cause, which was instituted pursuant to 

Chapter 71. of the Texas Family Code. 

FILED 

JAN 2 6 2015 ..~~ 

AT 10- SS A.M. 

C:-rklfr~~C'! .. TX 

Respectfully submitted, 

Chad Bridges 

Fort Bend County 

Asst. District Attorney 

Attorney for Applicant 

SBN: 00790369 . 

~D~ Tonika Davis 

Asst. Dist. Atty. Ft. Bend County 

Attorney for Applicant 

SBN: 24080003 

301 Jackson $treet 

Richmond, TX 77469 

(281) 341-4460 
I~ THE MATTER OF 

KAUSAR BAIG 

... ·.AP~LICilNT 

ANI) 

. .. . IRSHAD BAIG 

'. ·.· ',RESPONDENT 

. . . - .. 

AND ON BEHALF OF 

NO. 14-DCV-219,272 

§ IN THE 328th DISTRICT COURT -

§ OF 

§ FORT BEND COUNTY, TEXAS 

.·· .... ZA!D BAIG, .AMAN BAIG, KABIR BAIG 

ORDER TO DISMISS 

-·. ~ 

on . this -~-day of 

.. ·~~~~- ,th~ ,tl!¢~ipn pf the Assistant Attorney to <iismiss( the .'-

. :\~_'·::~~~e :~·~titled ~d numbered cause for the foregoing reasons~' The . . . ... :: ;;;'. · . ..:- :·: _._. :·:-..:·_::. :. ,. ' . . . ~ .. ·- •.-- ... _:_ .. ·_: .. · -~ "' · .. 

:: :~ouit : J1;ay~t}9: cpnsidered .· the .· pl~adings, and having }leard t:he 

,'·,.,,i·,"• :_;·:A,' 

~Vi~tmc;~ aJ1d ~nt of cotmael is satisfied that the above stat~ ... 

reasons · are good and sufficient to authorize requested 

~ . . 

... : 

· .. ··. 

TliEREFQR£, it iS ()RDERED, AD.JUDGED AND DECREED that the ~~e 

. _,_ f!,l1title.~ ~ _ n~rred cause of action be and is hereby Dismissed 

·. ·-::~:.:{:;~;~~op~·;: ~~~;u~C:e~ . ~·· · ·-~-- ..• , < sl:~ this ·~~day of 

··.":_ ~:~ .... ---~·.>:~:." .. -~~.··.· .• · .. -\-... ~. _;:: :.·.' •. ·:· .. ,,: :- ::!'"' -<: . .· ... :_. :: ·:· . . - - .. -:_~., . . : -.. :-.. 

·'· ... 

JAN 2 6 '1115 Jft'l. 

AT· ·· >jO _- 'SS · k M. · 

. . Cflrl~~;~1X .· .. 

. _·, .. . :. . ·;·. . . . ;~ .· . 

. . .. ·-
THE STATE OF TEXAS § 

§ 

§ 

§ 

§ 

I 

IN THE DISTRICf COURT OF 

FORT BEND COUNTY, TEXAS 

lf-.3 4- TR JUDJCW. DISTRICf 

Defaldant .. 

MOTION TO DISMISS 

il . 

OD this tbc l 3 day of ·flpNIL , 20 16 • the Sbde ofTcus. by IIJd dlrougb the 

below·namcdAssistant DistrictAttomey, respectt\IUy nquesta the Court to DISMISS the above styled IDdllUIIIben:d crimiDa1 

:;uin~chthedefeadantiscbqedwidltbeoffenseof ~ ~ Itt ~ ,fortbefollowing reasoa(s) to 

The evidcDcc is iDsufticicut to prove tbis cue beyoad a RI8IOII8ble doubt; 

lbe cte&iadaat was coe'ricted iD aaodler cue: Cause Numba(s): ________ _ 

Tbe complliDiDa witDas n:questl ctiaqUsgJ; • . 

Tbe cuc baa beeD Jefiled: Cause Number ~ fk..a 1 ULt FV 

The defendant is uuppreheDded; . 

The defendant is deceased; 

Tbc dd\:udant bu beeD paoted jrmi!Wiily D tbe clefcadant"l testimony; 

1bc defeDdaDI made fbll ratitutioa. iaeludiq fees IIJd Court COlli; or 

Odaer, to wit: 

Wherefore, it is prayed that the above cue be ctianjged with leave to rcfile, 

RespectfiiOy submiUed, 

~ L ·::: 

Allistaat District Attomey 

ORDER 

Motion to Dismiss is GRANTED on tbis thlli...e -~--- day of ........ __ .. _ 
THE STATE OF TEXAS 

vs 

IRSBAD ISMAIL BAIG 

D.O.B.: 1964 

Ricba Kllmar 

22.01 (a) (1) 

13990031 

DA CONTROL NO: 14-011029 

CHARGE: CAUSES BODILY INJURY FAMILY ARREST DATE: NA/SUMMONS 

VIOLENCE 

CAUSE NO: OFFENSE DATE: November 09, 2014 

~ COURT AT LAW N0\3 AGENCY/ AGENCY NO: MEADOWS PLACE POLICE 

DEPARTMENT/ 20145075477 

RELATED CASES: ASSAULT CAUSES BODILY INJURY CO-DEF: 

FAMILY VIOLENCE 

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS: 

Before me, the undersigned Assistant District Attorney of Fort Bend 

county, Texas, this day appeared the undersigned affiant, who under oath 

says he. has good reason to believe and does believe that in Fort Bend 

County, Texas, IRSBAD ISMAIL BAIG, hereafter styled the Defendant 

heretofore on or about November 09, 2014, did .then and there 

intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig 

by pushing him with Defendant's hand. 

It is further presented that at the time of the offense alleged above Zaid 

Baig was a member of the defendant's family or household or in a dating 

relationship with the defendant. 

c.n 

:Jao 

""0 , ::0 

(,.) 

-r-

-u m 

<a 

== 0 

en 

AGAINST THE PEACE .AND DIGNITY OF THE STATE. \D. 

SWORN TO .AND SUBSCRIBED BEFORE ME 

AFFIANT 

MISDEMEANOR COMPLAINT AGENCY) 
... 

~ 

STATE OF TEXAS 

v. 

\ 

IRSHAD ISMAIL BAIG, 

. Defendant, Pro Se :. ."l 

• No. t4-DCR-868oto 

) 

) 

) 

) 

) 

) 

~ ) 

-) 

'· ) . ) 

BEFORE THE 434m DISTRICT 

COURT OF FORT BEND COUNTY. . TEXAS ' 

. . . 

SWORN AWIDAVIT 

.. 

.. · 

,; 

. .. . ;. ~~ 

I, KAUSAR IRSHAD BAIG, herebY, herein swear upon oath under penalty of perjury according }· ·' 

· ·.,·tO law that the following declarations, a~ ~of fact, paragraphs 1 thru 5 are true · · 

· . · &nd. correct being based upon my own personal knowledge and experience. 

·1) 1 was bom August. 1972 and presently reSide at 11706 Nobility Drive in Stafford, Texas __ 

77477 and my telephone number is 281-658-2640. On or about November 09, 2014 at above · 

. ;o<iesidenCe my husband Irshad lsoiail Baig and I had a misunderstimdiilg; disagreement resrilting 

.. · ~-: in a·serious aigUJ;Deot concerning our financial position. · 

2) ·Although at the suggestion and ~istance of my friend_ I w8s taken to a nearby police station 

where I signed some form of Complaint ~gainst my husband, I~ too nervous to read the · 

· · · CcXnplaint so I merely signed at the place I was told to sign by policeman. 

3) Days- on or about November 20, 2014, I was questioned by C.P.S.:-~ informed that my 

children could be taken away from me by the State of Texas if I refused to sign papers for some. . 

"Piotective Order." Hooked at the papers and signed them for fear oflosing my cbildrei:t. 1 

~ rea4 those~ either. ._,-_, 

. 4) My children are my life and if they were taken away from me, I could DOt live. I believe Mr. 

,Enrico Fernando was one of the officers who talked to me. The State employees who 'talked with 

me were very nice but when it involved the S~ taking my cbil~ I heard and undeistOod 

very clearly and there was nobody that could quiet that tremendous fear in my heart. 

S) I never suffei:ed any actual offensive, provocative or painful physical ilguries from my 

· husband lrsbad lsiDai1 Baig at any time during the names, dates, places incident as a basis for 

·.. S1ate proseC'Qtion arising out of Fort Bend County, Texas. 

1 
_:~ ... :: 

Further Affiant sayeth not. 

Sworn To and Subscribed 

Before me on this J (gtft day 

of February, 2015 A.D. 

No 

~ AMIN M MEERZA 

.~My Commission Expires 

-:::::.:= June 1, 2016 

· .. :·.·:·.;·.-, .. 

Date: 02-\ \b \ ~0\ ~ · 

' 

2 
. ' ~.:.·~ 

. STATE OF TEXAS 

v. 

IRSHAD ~ BAIG, 

Defendant, Pro Se 

; ·" 

. ·.· ·: 

"" No.l4-:QCR-068oto 

) 

) 

) 

) 

) 

) 

~ ) 

~) 

. :. ) 

) 

BEFORE TilE 434TM DISTRICT 

COURT OF FORT BEND COUNTY. 

·, TEXAS • 

. . . 

SWORN AFFIDAVIT 

.'f_ . · : I,iAID IRSHAD BAIG, hereby, SW'ear upon oath under penalty of perjury according to law that 

.·.· .... the. following dec1ar8.tions, averments, ~-o( &ct, pamgraphs 1 tbru-6 are true and cOrrect · ,~based upon my own personal kno~e and experience. · . : . . 

. . '1) I was bom ~ 1999 and ~yreside at 11706 Nobilizy Drive inS~ 

· ''T~ -n411 and my telephone numbens 281-658-2640. On or about November 09, 2014 at 

.. · .. : -~ teSidence my JJatmal p8reuts, Irsbad father and Kausar mother were ilrguing about · · . . . . . . 

· · : ..:.iina:Dcial proble:ms. I was pm;ent with them. at the time and I reached over aod ~my · . · . · · ··-fiitber's mn in~ to voice my own~inion on the subjects they ·were~ MY father · .. : .. :,~ ii:l.a shocked or surprised manner. · . . . 

. ' :2)· My mother Kausar subsequently asked a friend to take her to the Police l>qJartment because 

$be \\185 still very angry at my. father. . Several days later I was interviewed by Child Protective 

Agency wo:dcers. 

· · 3). I never did and still do not regard the argumentive language or actions ~fmy father :fi.sbad·or 

m.Y mothef Kausar either provocative or offensive· to or toward my personal being; throughOut · ·1he entire DlOIJth ofNovember 2014. . . . 

4) I never witnessed any actual bodily ugmy of my mother Kausar or my own pen;on during 1he . 

: NovCIIlber 09,2014 argument~ my mo~ ~and filther lrsbad oVa: financial iSSues . . Jlfei1her was I involved in or aware of any o1her: such arguments during the year of2014~ · ·· 

. . 

· . ..·· 5) On or about. November 20, 2014 both my mother Kausar and m;yself (.Zaid) wen,qUestioiied : · 

. : ·.,by c.P.S. ()6icer ENRICO FERNANDO ~which time my statements were pUt on tape · :. · .. · ~- Ai that time I specifically declared "I am not scaled or afraid of my fidher Irsbad". and · 

1 
"I acted to intervene .. (idem sonan) (para. 1 supra.) with my father Irsbad at, during the time of 

argurilent the State's erroneous prosecution of my father is preSently based upon. 

6) Based upon my own personal experience, in this subject matter under Cause No. 14-DCR068010, I can see no rational cause for my father lrshad to be put in jail or the tumultuous pain 

caused in my family during separation because of a "protective order" subsequently dismiSsed by 

· Judge Ronald R. . . I suffered no personal injury or offense at the hand of my father 

Irshad Baig at any time incident to State ofTexas Cause Number 14-DCR-068010. 

Fmtb.er Affiant sayeth not. 

ZAIDBAIG 

· Sworn To and Subscribed 

· Before me on this /61ft day 

· of February, 2015.AD. 

Date: ,,.oz..•"" 

2 
STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se ~ ":! 

No. 14-DCR-068010 . 

) 

) 

) 

) BEFQRE THE 434 TH DISTRICT 

) COURT OF FORT BEND COUNTY, 

_) TEXAS 

) 

-) ~ . 

' ) 

) 

SWORN AFFIDAVIT 

I, IRSHAD ISMAIL BAIG, hereby, ~in swear upon oath under penalty of perjury according 

to law that the following declarations, averments, statements of fact, paragraphs 1 thru 6 are true 

and correct being based upon my own personal knowledge and experience. 

1) I am the named Defen~ in Cause No. 14-DCR-068010 arising out ofFort Bend County, 

Texas. · 

2) I am proceeding pro-se in my own defense in said (para. 1 Cause Number,) being fully aware 

of the possible pitfiills, dangers of such representation, as well as being aware of my State of 

Texas and United States (federal) rights to defend myself personally. 

3) · I have a sound, secure belief based upon reasoned study of applicable law that I have also 

· . filed numeroUs Other pro-se pleadings material and relevant to the disposition of all substantive 

due process of law issUes, questions arising out of the proceedings in Cause sub judice. 

·. 4). • I have a sound, secure belief based upon a reasoned study of applicable case law authority, 

both state and federa4 that there is either no substantive evidence or only a scintilla of evidence 

eXisting that can objectively support the State of Texas felony charges I am on trial for in Cause 

sub judice. 

5) I formally declare, aver and propose that any fwther prosecution of Fort Bend County Gause 

Number 14-DCR-068010 based upon presently non-existing evidence would be an abuse of 

·Texas taxpayer funds. However, I do not have authority to remedy. 

6) I further declare that at anytime incident to the substantive questions in Fort Bend County 

Cause Number 14-DCR-068010, I do not recall ever verbally or physically abusing or injuring 

any member of my family and specifically not my son ZAID nor my wife KAUSAR. 

1 

, 

' 
Further Affiant sayeth not. 

· ...... . 

AMIN M MEERZA 

My Commission Expires 

June 1. 2016 

IRSHAD ISMAIL BAIG 

Date: 

2 
., 

I 

STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No.15-CCR-180026 

County Court at Law No. 3 

Fort Bend County, Texas 

\ A11AWM~t.J-r ____ A1.j 

ORIGINAL tfe~~:s/ yl'\' 

in the f('f\ "'\~ records. 

Copies NOcompared. 

~URA RIG:f, County ClarK 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

B~~~'IJGa c~~lr3 

FO~~'{ () \ \\\~ 

£('$Off\C~ 

"''t1 ~:no\\~ FORT B~ COUNfY, TEXAS 

AFFIDAVIT OF NOLLE PROSEQUI 

I, ZAID IRHSAD BAIG, hereby and herein swear upon oath, under the penalty of perjury 

according to law that the following declarations, averments, statements of fact paragraphs 1 thru 

5 are true, correct being based upon my personal knowledge and experience. · 

1) I was born December. 1999 in the United States and am a natural citizen thereof. I 

presently reside at 11706 Nobility Drive in Stafford. Texas 77 4 77 and my present telephone 

number is 281-658-2640. 

2) I am the alleged Complainant in the above styled, numbered Cause of action due to erroneous 

state action(s) of Fort Bend County Officials. At no time whatsoever did I ever ask, request, 

seek or desire to file any type of legal action against my natural father Irshad Ismail Baig 

during the year 2014 and to date. 

3) I was present, on the scene witness to all confrontation episodes over financial issues 

between my Mother Kausar Baig and Father Irshad Baig during November 2014 and at no 

time was there any actual, physical or emotional injury suffered by my own person as a result 

of Irshad Ismail Baig's actions or omission of action.. 

4) On or about November 20, 2014 both my mother Kausar and myself were questioned by 

State C.P.S. officer Enrico Fernando during which time my statements were tape recorded. At 

those times I specifically declared "I am not scared or afraid of my father Irshad." 

5) Based upon my own personal experience in the subject matter under Cause No.180026 I 

cannot see any rational cause for my father Irshad to be prosecuted for something he simply 

did not do. Furthermore, it is repulsive to my mind to witness a State Agency twist facts 

around to make appearances that simply do not exist, such as the charged Information saying 

"did then and there intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig 
,. 

by pushing him with defendants hand." I hereby specifically declare nobody, including Irshad 

Ismail Baig, ever ca~ me any bodily injury as fraudulently expressed and charged by State 

officials in Cause No. 180026 supra. 

Sworn to and Subscribed 

Before me on this 3~y 

of April 2015 

- . ' .. ~ 

····--.~-~-~-

AMIN M MEERZA 

My Commission Expires 

June 1. 2016 

ZAIDBAIG 

Date: oolj_ 5o-;- 2015 

'v 
STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No. 14-CCR-177950 

County Court at Law No. 3 

Fort Bend County, Texas 

) 

) IN THE COUNTY COURT AT LAW 

. ) N0.3 

) 

) FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

AFFIDAVIT OF NOLLE PROSEQUI 

I, KAUSAR IRSHAD BAIG, do solemnly swear, aver, declare upon oath, under penalty of 

peljury, according to law that the following two paragraphs are true and correct based upon my 

own personal knowledge and experience. 

1) The only reason I ever signed any type paper work or document related to Fort Bend County, 

Texas Misdemeanor Cause Number 14-CCR-177950 was because I was placed in serious fear of 

losing parental custody over my children due to open threat by State of Texas employees 

interviewing and questioning me about a family incident. 

2) I do not intend to prosecute, neither will I participate in any future court or State sponsored 

activity related to Fort Bend County, Texas Cause Number 14-CCR-177950. 

Further Affiant sayeth not. 

·' 

RECEIVED 

APR 20 2015 

DISTRICT ATTORNEY'S OFFICE 

IRSHADBAIG 

11706 Nobility Drive 

Stafford, TX 77 4 77 

, Phone: +1 281 6582640 

COPY ORIGINAL filed on J.;f - o. o - J s 

in the m r $ ct records. 

Copies NOT compared. 

LAURA RICHARD, County Clerk ·.. ~ . ·i (.) Bv ct?J · 
35615515 

1111111111111111111~11111111111111~ ~I 

STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No. 15-CCR-180026 

County Court at Law No. 3 

Fort Bend County, Texas 

) 

) BEFORE THE COUNTY 

) COURT AT LAW NO.3 

) 

) FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

AFFIDAVIT OF NOLLE PROSEQUI 

I, ZAID IRHSAD BAIG, hereby and herein swear upon oath, under the penalty of perjury 

according to law that the following declarations, averments, statements of fact paragraphs 1 thru 

5 are true, correct being based upon my personal knowledge and experience. · 

1) I was born December 24, 1999 in the United States and am a natural citizen thereof. I 

presently reside at 11706 Nobility Drive in Stafford, Texas 77477 and my present telephone 

number is 281-658-2640. 

2) I am the alleged Complainant in the above styled, numbered Cause of action due to erroneous 

state action(s) of Fort Bend County Officials. At no time whatsoever did I ever ask, request, 

seek or desire to file any type of legal action against my natural father Irshad Ismail Baig 

during the year 2014 and to date. 

3) I was present, on the scene witness to all confrontation episodes over financial issues 

between my Mother Kausar Baig and Father lrshad Baig during November 2014 and at no 

time was there any actual, physical or emotional injury suffered by my own person as a result 

of Irshad Ismail Baig 's actions or omission of action. . 

4) On or about November 20, 2014 both my mother Kausar and myself were questioned by 

State C.P.S. officer Enrico Fernando during which time my statements were tape recorded. At 

those times I specifically declared "I am not scared or afraid of my father lrshad." 

5) Based upon my own personal experience in the subject matter under Cause No.l80026 I 

cannot see any rational cause for my father Irshad to be prosecuted for something he simply 

did not do. Furthermore, it is repulsive to my mind to witness a State Agency twist facts 

around to make appearances that simply do not exist, such as the charged Information saying 

"did then and there intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig 
by pushing him with defendants hand." I hereby specifically declare nobody, including Irshad 

Ismail Baig, ever caused me any bodily injury as fraudulently expressed and charged by State 

officials in Cause No. 180026 supra. 

Sworn to and Subscribed 

Before me on this 3D~ay 

of April 2015 

~blic Fort Bend County, Texas 

..3' J ~ 0 :...: 

0 ..::r 

UJ 

::c rt.'&~ I.L.Jt0.. -:' :!~ u .... 

. >-'.::J 

...-'1 c;! t-c zc 

>- ~ ~r5 lt .. c:: 

!...,"""':; 

X: ~u~ .o => u..· 

~~ 

ZAID BAIG 

Date: (}' LJ-j () ·-;- 2015 
I ,' 1 • 

No. 15-CCR-180026 

County Court at Law No.3 

Fort Bend County, Texas 

) 

15-CCR -180026 

MOTI 

Motion (No Fee) 

illlllllllllll\111 

STATE OF TEXAS ) BEFORE THE COUNTY 

) COURT AT LAW NO. 3 

v. ) 

) FOR 

IRSHAD ISMAIL BAIG, ) 

Defendant, Pro Se 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

DEFENDANT PROSE MOTION TO HOLD ALL PROCEEDINGS IN ABEYANCE 

UNDER INSTANT CAUSE NUMBER 180026 PENDING DISPOSITION OF 

ARTICLE 11.09 T.C.C.P (2010) HABEAS CORPUS ACTION NOW BEFORE THE 

TEXAS COURT OF CRIMINAL APPEALS IN AUSTIN, TEXAS 

TO THE HONORABLE JUDGE OF SAID COURT: 

Comes now, IRSHAD ISMAIL BAIG, your Defendant pro se in Cause sub judice and 

respectfully moves the Court to place all process in judicial abeyance on the instant Cause of 

action pending final subject matter disposition by the Texas Court of Criminal Appeals. It is 

well established law that two different courts of the same sovereign authority may not 

entertain subject matter jurisdiction at the same time frame. 

Case Facts 

1) On or aboutAprill3, 2015, the 434th District Court ofFort Bend County, Texas 

dismissed prosecution under Cause Number 068010 at State prosecutor request.-

However, on the same day, the same prosecutor re-filed the former charges relying on 

same facts, subject matter in County Court at Law No. 03. Once ,a criminal case is 
dismissed by proper judicial authority it is deemed by judiciary that the case never 

existed. The new Cause Number became 15-CCR-180026. 

2) On or about May 10,2015, Defendant filed his prose Application for Writ ofHabeas 

Corpus, Article 11.09 (pre-trial habeas action) in the Texas Court of Criminal 

Appeals. See: EXHIBIT "A" attached hereto, at paragraphs 11, 13 page 4 thereof, also 

paragraph 16, page 4. 

PREMISES CONSIDERED: 

3) Your Defendant prose respectfully submits to the Honorable Judge here that significant 

substantive evidence and due process of law legal claims are timely, appropriately before 

the Texas Court of Criminal Appeals that warrant complete dismissal of all fact related 

criminal charges arising out of Fort Bend County against Defendant 

4) Because the higher court has total habeas corpus pre-trial jurisdictio~ over subject matter 

in Cause subjudice, the instant court is mandated to GRANT Defendant's instant pleading 

and enter appropriate notice of ABEYANCE onto the Court's docket sheet, thereafter 

directing the Court's Clerk to timely notify all interested party(s) hereto. 

____ ,2015 

MOTION GRANTED/DENIED 

PRESIDING JUDGE 

Respectfully Submitted; 

(\~y -~ 

IRSHAD ISMAIL BAIG 
STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No.lS-CCR-180026 

County Court at Law No.3 

Fort Bend County, Texas 

) 

) BEFORE THE COUNTY 

) COURT AT LAW NO.3 

) 

) FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

CERTIFICATE OF SERVICE 

I, Irshad Ismail Baig, hereby certify I have personally hand delivered true, accurate 

copy of foregoing PRO SE MOTION TO HOLD ALL PROCEEDINGS IN ABEYANCE to 

the District Attorney Office of Fort Bend County, Texas 

\s:- A :?o Jljt-)~ '2015 

Irshad Ismail Baig 

·n 

-i 

m 

0 
• 

'- ~l~. '· 

. ..: f 

:.•· 

No. 15-CCR- 180026 -

-l~DCR- 868810 · 

County Court at Law No. 3 

Fort Bend County, Texas 

) 

STATE OF TEXAS ) IN THE COUNlY COURT AT LAW 

) N0.3 

v. ) 

) FOR 

IRSHAD ISMAIL BAIG, ) 

Defendant, Pro Se 

) 

) FORT BEND COUNTY, TEXAS 

) 

IN THE COURT OF CRIMINAL APPEALS OF TEXAS 

APPLICATION FOR WRIT OF HABEAS CORPUS 

(T.C.C.P. ARTICLE 11.09; 11.04) 

Applicant: IRSHAD ISMAIL BAIG 

Date ofBirth: April 07, 19~ 

STATEMENT OF CASE 

1) On or about November 18, 2014, Kausar Baig, wife of Applicant herein, 

made a criminal Complaint with Meadows Police Department of Fort Bend 

County, Texas implying family violence may have occurred. 

2) A judicial Protection Order was applied for by C.P.S. (Child Protection 

Service) and was summarily granted, temporarily prohibiting Applicant from 

associating with or contactirig his immediate family in Cause number 14-DCV219, 272 on or about December 01, 2014. Earlier, on or about~~~VtEJ} . _ · MAY 13 2015 

14th, 2014, after C.P.S. officers had interviewed my wife, she was threatened m the 

DISTRICT AnORNEY'S OFFICE 

Page 1 of6 
.• ... e· 

following manner ''If you do not sign an Affidavit against your husband, today we 

will take official custody against your three children and put them in a State 

Home." 

3) After the Protective Order was granted, the state of Texas as well as the 

County of Fort Bend, Texas elected to file and prosecute subsequent felony and 

misdemeanor charges against Applicant under Cause Numbers 14-0CR-6801 0 

(felony) and under 14-CCR-177950, December 2014, January 2015. 

4) On or about January 26, 2015, the state ofTexas moved to Dismiss the 

protective Order and Court granted same. See: Attachment 1. 

5) On or abotitApril13, 2015, the state ofTexas moved to Dismiss felony 

prosecution in Cause Number 14-DCR-68010 tore-file same as Misdemeanor in 

Cause Number 15-CCR-180026, subjudice. 

6) Applicant is now before the Court seeking habeas corpus relief from what he 

perceives to be unwarranted judicial harassment and blatant abuse of tax payer 

funds. 

LEGAL CLAIM 

7) Applicant is presently restrained of his liberty and property interests in Fort 

Bend County, Texas under color of State of Texas law in manner contrary to and 

inconsistent with the Constitution and law of the United States of America and 

specifically the FOUR1H, FIFTH, SIXTII, and FOURTEENTH Amendments 

Page 2 of6 

. .. 

. • •. -. , ..••. ,, ·-····· •. ,•-_,.. ·'····· 1 •. ~---· •<•;., --·~-.: •. :.--.~1<>~.-
thereto. 

8) Applicant herein urges the writ of Habeas Corpus to issue forth against Fort 

Bend County Misdemeanor Complaint/Information number 15-CCR-180026 and 

Dismiss with Prejudice all charges incident thereto. 

CAUSE 

9) Applicant is a resident of Fort Bend County living at 11706 Nobility Drive, 

Stafford, Texas, 77477 thus in personam jurisdiction is satisfied. Jurisdictional 

authority is under T.C.C.P. Article 11.09 (2010); Article 11.04 (2013). 

1 0) By virtue of criminal Complaint/Information in Cause number 15-CCR180026 in Fort Bend County, Texas there has arisen applicable Bail Bond restraints 

as well as numerous and continuing open court appearances which mandate lost 

working days (Applicant recently laid off after 17 years because of taking too 

much time off for courts). All of paragraph 10 restraints conclusively establish 

injury to both Applicant's liberty interests and vested property rights which are 

severely injured. U.S. Supreme Court declares money as property and 19¢ injury 

states valid Claim. 

11) Applicant complained of liberty restraint has been in effect since on or about 

December 15,2014 some 130 days of restraint with continuing effect has elapsed, 

regardless of fact Applicant admonished the diverse judges, D.A., trial courts that 

Applicant desired a fast and speedy trial on merits. Applicant has not yet been to 

Page 3 of6 
'. 

trial and the State Prosecutors have NO valid evidence to set before a jury beyond · 

that of mere speculation which cannot sustain a conviction. BARKER V. WINGO 

_ S. Ct._ (1972); WEBBER V. STATE, 29 S.W. 3d 226 (P.D.R ref.) Tex. App. 

Hou. (14th) 2000; T.C.C.P. Art. 38.03 and progeny. 

12) Finally, Applicanfs constitutional rights are essentially a federal question 

and the instant Pleading is filed to exhaust state remedy at this point. 

13) Applicant is supporting his legal claims herein with copy(s) of authentic 

evidence via sworn, notarizedAffidavit(s) and relevant Fort Bend County 

documents. 

14) Applicant has submitted herewith at Attachment A, B: State MOTION TO 

DISMISS PROSECUTION in Fort Bend County, 434th Judicial District, Cause 

Number 14-DCR-68010 and State INFORMATION in Cause Number 15-CCR180026. 

15) Applicant has submitted herewith as E~ITS 2, 3, 4 the sworn, notarized 

Affidavits of KAUSAR IRSHAD BAIG, at #2; ZAID IRSHAD BAIG , at #3; 

IRSHAD ISMAIL BAIG, at #4 

16) At paragraphs 3, 4, 5 ofKAUSAR's Affidavit there exists material facts of 

fear that has coercion implications; irrebuttable declarations which is clearly 

negative of State criminal statutes required mens rea criteria. 

17) At paragraphs 3, 4, 5 of ZAID's Affidavit there exists material facts, 

Page 4 of6 
negative of State criminal statutes required mens rea criteria 

18) At paragraphs 4, 5, 6 ofiRSHAD's Affidavit there exists .material fact 

declaring negative impact upon State criminal statutes and specifically those 

relating to a person's actions or omissions under·severe duress as established by 

sworn Affidavit ofKAUSAR IRSHAD BAIG, Exhibit 2 herewith. 

19) A cursory review of all State evidence in this case even including its 

companion cases should reveal the State's entire prosecution of Applicant here has 

evolved from a woman under duress seeking only some kind of temporary 

protective order at suggestion of a neighbor/friend when neither ever realized the 

State (local) prosecutors_ could or would take more extreme action against her 

entire family. Regardless, however, the status quo of the present State position is 

frivolous at best. Please take note also of the Sworn Affidavits of Nolle Prosequi 

on file with Fort Bend County Court and Prosecutors attached herewith, at 

Attachments Aland A2. 

PREMISES CONSIDERED: 

20) Applicant respectfully moves the honorable Court to DISMISS with/without 

Prejudice the State Information in Misdemeanor Cause number 15-CCR-180026. 

So Moved and Prayed 

IRSHAD ISMAIL BAIG 

Page5of6 
·e .! 

ORDER 

On the _day of , 2015 came on to be heard the Application for 

WRIT OF HABEAS CORPUS under Texas Code Crimina] Procedure, Article 

11.09 (2014) and having given due consideration to same, including the evidence 

submitted therewith, the Court is of the opinion the WRIT be 

GRANTED/DENIED and on this same day the State Information is· 

DISMISSED/ ALLOWED to proceed. 

Date: _____ ----7 2015 

Presiding Judge 

Page6of6 
STATE OF TEXAS 

v. 

· IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No.lS-CCR-180026 

County ·court at Law No. 3 

Fort Bend County, Texas 

) 

) IN THE COUNTY COURT AT LAW 

) N0.3 

) 

) ·FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

CERTIFICATE OF AUTHENTICITY 

I, IRSHAD ISMAIL BAIG, Habeas Corpus Applicant in above styled, 

numbered Cause of Action, hereby, herein swear upon oath under penalty of 

perjury according to law that ·all EXHIBITS and ATTACHMENTS evidentiary in 

scope, nature iticluded with instant Certificate are true and correct photo copies of 

the Original documents on file with Fort Bend County and District Clerk Offices in 

Fort Bend County, Texas. 

Notary Public, in and for: 

iRsHAD ISMAIL BAIG 

11706 Nobility Drive, Staffoid, Texas 77477 

.~fl'Y-~-'I:-: ·-- .. ·-' 

AMIN M MEERZA 

My Commission Expires 

June 1, 2016 

.... . .. ' ..... -...• ~ " . · ..•.. ,.. '. . ... '···· .. :• ·, ... ·" .. -~.. "'· . ' ... 
IN THE MATTER OF 

KAUSAR 81.IG 

APPLICANT 

AND 

IRSHAD BAIG 

RBSPONDBNT 

. AND ON BEHALF OF 

NO. 14-DCV-219,272 

I I 1 ] ,I ljf I j , 

: : ; ; i J:i· 1: ,, 

: l ' ], I' I II 

1 • ; I l ~ J 

§ IN THE 328th DISTRICT COURT 

§ OF 

§ FORT BEND COUNTY I TEXAS 

ZAID BAIG I AMAN BAIG I KABIR BAIG 

MOTION TO DISMISS 

COMES NOW, Tonika Davis, Assistant District Attorney.of Port 

Bend County, Texas, on behalf of Applicant and respectfully 

requests this Court to Dismiss Without Prejudice, the above 

entitled and numbered cause, which was instituted pursuant to 

Chapter 71. of the Texas Family Code. 

FILED 

JAN 2 & 2015 .l~ 

Ar~··ss A·u. 

ClltUIII.tt'l::C. TX 

Respectfully submitted, 

Chad Bridges 

Fort Bend County 

Asst. District Attorney 

Attorney for Applicant 

SBN: 00790369 . 

~J:):i)L4u£) Tonika Davis 

Asst. Dist. Atty. Ft. Bend County 

Attorney for Applicant 

SBN: 24080003 

301 Jackson Street 

Richmond, TX 77469 

(281) 341-4460 

' ..... '> ···' • ' ~ ............. ~-' ... ·.~~ ...•••.• 
. ·."; ~<. . 

I· . ·.· ::~~~~;-~~-: :"~~~j\:t~f·'~~- • 

NO. ~4~DCV-219_; 272 

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s IN. THB·.328th. DISTJti:CT C<>tJR+ .. . . . . . .. · . . . . .... -~., ·. ·.. . ·. :.-."' ... , ... i··· .. 

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.-._ ...... ··-·-···-·' •. , ~ .! . . .. .,.,.:;, .. . . .._,, :::. . ,.~ .. ..:. .. 
NO. Ill--De.~- 68010 

I 

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I 

I 

I 

MOTION TO DISMISS 

IN 'I'JIE DII'I'BICT C01JRr OP 

il . . . 

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22.01 (&)(1} 

1.39SI0031 

15-cCR.,-111111211 

CCII 

l'.lllllplllal 

IP"I-RS-==D-· n-=I-SMAI.........,==-L--BAI""""*'"""'G=--......... --o::o==o===-.....,.--.......:="-==--oa=:===_-~f --

D.O.B.: 64 DA ~NO: 14-011029 

CHARGE: ASSAOLT CAOSES BODILY INJURY FAMILY ARREST !lAD: NA/SUMMONS 

~: November 09 2014 

AGBNC'Z/ AGBNCY NO: MEADOWS PLACE POLICE 

DEPARTMENT 20145075477 

BELADD. CASES: ASSAULT CAUSES BODILY INJURY CC>-DBli': 

VXOLEN'CE 

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS: 

Before me, the undersigned Assistant District .. Attorney of Fort Bend 

County, Texas, this day appeared the Un.dersign.ed affiant, who under oath 

says he has good reason to ._believe and does believe that in Fort Bend 

County, Texas, msBAD X.SMJKU. BAXG, hereafter styled. the Defendant 

heretofore on or about N~ · 0.9, 2014, did then and there 

intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig 

by pushing him with Defendant's hand. 

It is further presented that at the time of the offense alleged above zaid 

Baig was a member of the defendant's family or household or in a (i(lting 

relationship with the defendant. 

·-= en 

~ _, ;s 

- - w r-· 

.., . m : 

(A) 0 .. 

(11 

AGAINS!r TBE PEACE MID ·DJ:GRJ:TY OF. "fBB S'rAB. U) • 

. -~ ...... : ., .. , . ~- .,.. ·-~~· ··"' .:··· ••• , >-:! . ....... ~· 
' . - ·~ 

~·:~ 

.. STATB OF TEXAS 

v. 

IRSHAD ~BAIG, 

. Def-'ant, Pro Sc 

':. s 

) 

) 

) 

> BEFORE ~43418 DISnUcr ) cot1kr OF FORT BEND CO~ 

) TEXAS 

·~ ) 

~) • e .-r, ) i 

) 

·.!Ill>_ 

·~ ·;. 

S.WOBNAmDADI . ~ ·.:· •. ·;.·!\· 

. ·I. icAusAR JRSHAD BAIG, haebj, ha:ein swe&rJUPCBl oath uadt:l' pe:uaJ:ty of pea jury accou1iug }-- !. 

.· /1DJawthat6efbJJowiasdedazationss avwnecds, Sl(llteiiWdsof fad,pamgaBjokldJmS 81e1rue .. 

. · .. · 8iKi ~being based upon my own pemaud koowledge aod.apc:rience. · ... 

'1) lwas born August• tm aDd prC!ICidly :remde at 11706 Nobility Drive in~ Texas.';... 

T/477 aDd my 1f!1cphnne mmberis 281-658-2640. Oa.Ol' about'Nowmber 09, 2014 at &bow · 

. ;;'iesidmee my busbalwJJ:mhad.Jsmail ~ aod I had a mism..Jo•••...tmc; cfisa&recme:ut lf'881ting · 

. ·.- . ., in &serious acaoum ccmcanina our finanr.JaJ position . · 

· :.. 2) .. · Aldlougb. at die sugesticm aDd ~·.-e of my fi.iead: I was 1Bkm to a Di:at,by poJlce Sbdion . 

whtft J. sigDed some fiJrm of Complaint 9inst my Jmsban:d, I~ too :oea:vous to read the · ~·· 0Rnp•iol so I maely siped at & pJace I was 1Dld 10 sip by policeman 

. . l) Days Jater. on or about November~ 2014, I was qnestioned by c.P.S.::w.f irdic•ned tbat~ 

· c:h,iJdral c:ouJd be~ away from me by 1he S1Bte ofTexas ifl mtbsed to sip papcm mr ~-

.. · :"PioCective Otdm:." I.Joobd at the papas aod sipecl than for fear oflosiDg my cbi1dn'liL. I . .w.-rea41hose pap(D either. . . . .r :i. . . 

. ,/ 

.4) .My dlildleD a my 1ifC aod if1hey wae 1akal away from me, I could~ 1M. I believe Mr. 

·.Emico Fernando was G:Je of 'the officers who 1aibd to me. 1'he S181e c:mplo;ees who 1aJbd wi1h 

. 

me.'WaeverJ 

very c1eady aDd 

Dice 

1herc 

but'Wbal 

was nobody 

it~ 

dJ8t could 

the S.1BkiDgmy 

qoit:t 1hat tra•MW''*NJS 

cbikkeD, 

fear 

I heml&Dd 

in~ heart. ~ 

S) I~ sufti::&d.aay actual offeasive. }imvocative or painfbl pJJ:,sical il:jmies fi:om my 

· ..,._d llshad Jslil8il Baig at any time dmiDg the~ dales. p1aces incideat as a basis 10r .· · ... Stale ~.arising out ofFort BeDel County, Texas. 

1 

·. ·:· ... , •. . . ··'.' . ' .. · ~ ·-· , __ . -- ·" . -. " . • • ..., .•••.. _, •. _ ... , ... - - 1 .. ___ . ·'·· ._, ., • •••• ;, --~ • -.-. /':",. -~--. ' .. : ~- -· •.. :.·- .. <.., 
I· 

I -· ··. ~ ... ~ .---· 

Further .Affi.aDt sayeth not. 

Sworn To and Subscribed 

Before me on 1his ~day 

·ofF~ 2015 A.D. 

·.~':. 

.. 

Date:·o~l \b \2-0\ ~ · 

2 

:· .. · . ,..,. : .. ; .. : ... -····· · ....... . 
·!._s::.., ·:J.- . -. - --~" . ... !. 

Qefeadmt. ProSe 

·, .. 

. ' 

) 

) 

) 

) 

) 

) 

-~ ) 

-) 

-~· ) 

_) 

BEFOJm.THE 434m DISTRICT 

COUIUOFFORTBENDCo~ ·, TEXAS . . ... ·. 

. . . . . . 

.,._ 

. ,. .... . . . • '. J • 

-)·· 

.... ~ . swOBNAfliP•vn .. • . . ,j . . . . . ;_ . '. ·_:·... ,· . . . . -.. -t . . . -:::I,·~ lRSHAD BAIG, haeby, ~upmOidh ubderpeaaltyofpajury ~tD~-1blit. · -.· · :·_-_::,tbQ-~dedanidons,avaowds,stataa!C?•'sc(&ct,paragraphs 111Jro.6am1rueml4conect : .· · · .. ·. -~~ upalllDJOWDpal"lll ~&Ddexpa:ieace.. .... : . . . . .. . 

. . ·, _'·:l) I_Wiis bam~·1999 aad~esL:atly ~~ 11706Nobiliiy Jlriveia~ ·~T--·77417 aud my~ 1JP!Dber IS 281--658-2640. 0B: or ilboutNovemhcr09, 2014 ·- . ~ ·. :. _..J.eSidenc:e my11Bf11Dtl ~ I:rihad_&lb&!:t aad 'J'anpr~wae ..... h. about · · ·. · : .' 

_. · · ~·.: .... ;~.1~ IwaspcDJtwidliban•1bc1imeaadli"JJf"hedoveraail~.a.f :- ·. ·. · 

. · . · · _--.~· ~-ja, •i•••q,t1o voice my own-opiuionon1be subjects ~Wale m....-..... Mf ...... · :. · · · · - .... .._... iba Wor piwlmamM& · . . . ,.· .. ·;-'~.m.a '" . - . . - .... _. '.·:,·-· 

. , · . . :2l· )q JIMIIfher :g.,... SPbeeqlw*'ty aabd a friald 1D 1ab her to 1he Polk:e ~lmtiut-ieamae 

. • was.sliD very 8Df1'1 at my_falhl:r.·. Sewiral daJs later I was~ by Cbild Protective .. -A~woaba.. . . ~ . 

. . : 3)) aever'ciidaad still do DOtn:pnl1he•llgUilwdive langpaae ~dons ~my ~:*·or_.·. · mj~·Kausar ei:lha-povccative oro&imive·1D ~1Qwad~pascmal beiD& ~ . _ . . :_·~~~2014. . .. 

. . 

4) . I~ wit•M md any actual bodily~ ofmyJIIOdla-TC~ or my cnmpeacm~dJe .. ·: ~-09,2014mawatent1M~mmy~K~aad~lrsbado¥rzfinauQati8ies. 

_ Neiibriw&S IimOived in or aw~i~e of my~ such aqpaneiits cludDg the,_. of2014~ · · · .. . •. . . . . : . . . 

. . ·._: .. :·:5): Oa'!'f.,_NOft.lllbez20,2014bothmyJDOti.rKansaraod~ ~~~ :: 

·. : ·:··J;,y·c.P~~ENRICO FERNANDO ~which tii:Bmy slatHaods."wiDpit'oo.-.·_- -... · .. . . -~ .Ai 1hat1ime 1 speci&a1ly decJmed "1: am DOt scai'ed or 8fiaid of my~ Iailar.a.- · ' · . ·.. . ... ·. -~ ··~. . . .. . . . . • . . . . . .\ •. . . • ·<·. . .... 

. .... 

1 
. . . ~. 

"1 acted to imerveoe" (idem sonan) (para. 1 supra.) with my father Irsbad ~during the time 'Of • 

argmDent tbe Stare's erroneous prosecution of my father is pteSeutiy based upm. . . . . 

. 6) Based upon my own personal experi~ in this subject matter under Cause No. 14-pcR~ 

()68010, I can see no rational cause for my father Irsbad to be put in jail or tbe tum~ pain · · 

, ·cause4 in my family during separation because of a "protccti~ Older" subsequcmly dismiSsed. by 

·. Judge ~d R. . •· I suffeted DO personal injury or o1fense at 1he hand of my fidher 

· lrsbad Baig at any time~ to State ofTexas Cause Number 14-0CR-068010 . 

. . Further Affiant sayeth not. . . I . 

ZAIDBAIG 

· : · ·.sWorn To aod Subscn"bed 

. · .. Before me on thiS {&/Ia day 

· ofFetiruary, 2015.AJ> . 

... 

2 
• No.14-DCR..eA810 

.. · · STATE OF TEXAS 

.. v. . . \ . 

. . IRSHAD ISMAil;BAIQ -

) 

) 

) 

) 

) 

BEFQRB mE 434'01 DISTRICT 

~OFFORI'BEND~ 

.• . , -) 

•) 

-) 

J.i ) 

..) 

SWORNAD'JDAVIT 

"· TEXAS 

.... 

·. · J:'~~BAIG,Iaebyr~swe&rvponoaih ~paiahy ofpajury accordiDg .'[ 

. ' w.tinlf.dad'6ie;1bllowDw clor;lealioas, an:piMjdS; slldo••ds of fact, paragmpbs 1 thm 6 are true . . alalConect beiDg based upaD my own peaoaaJ kDow1edge aod axperieDce 

· · 1).>'-{• tbe Daaecl ~in Causc,"No. 14--:pcR.-068010 arising out ofFoit ileud·Coum:y, . -~::-. . . . 

.•. : 

.2)·' ·1 ~.~po-se in my own defeDse in said (pa:a. 1 Cause Nnmbel;) being fbDy aw&Ee · 

.• -..po91P"bli1'Jiid8Ds. ..,.sofsaducpc&adaliDD, as wdl·as be:iog awmeofmy Stale of 

.. ~·aDd United s.a.s (fiedera)} rlibls 1D detead mySelfpasooally. . 

. . . ·]):·I~ a SOUDd, secum Wbased ~ JJCamnrd SIDdy of appJirable Jaw1hat.J have also 

.. :' filed....a.oiis Olhrrpm-sie pin rtmgs,...,. aDd ICievaad: to 1be ~of an substatdive 

.· ~ ~-oflawissUes, qur:sdoDs arising out of the. proceedinp in Qmse ~judice. 

· . ': :·4) ::; . I~ a . .-ad. &ec;1lie Wbased upon aKBsonecl study of appJirable case law autholey, 

. ~ ...... fedrnl,.1bat tbeae is ~DO subsfa .. tiYe mdeace or only a sciublla of evideDce 

eciafinitbat ciill~ suppm;t1be SUB ofTexas felony chalgesl am on trial·for in Cause 

sUbjudice. . 

S) · ·lfutmaJlY cJecl1n; avec aad popose that 8J1'f :&ulhet ~ ofFort Bead CoUDty Q1use 

~ 14-IX!R:-068010 based upoa prwc::ad:y DOil-CZisdDg evideDce would be an abuse of ·T~·Iiuqayer fbads. BowCver; I do~ have jpcfla;u ity 1D tanedy. 

· .. 6) •. I tbdher~~ ataai}time incidemtto 1htSubstacdjve ~in Fort Bend County . ·Oiase Numhe:a-14-DCll-068010, I~ DOt recall~ 'Vabally or physicaJly abusing or i:ojurlDg 

.any fneiudi« of my family aod spedficaUy Dot my sanZAID nor my wife KAUSAR. : . 

1 

- •• • •••• .,.,_., .. - "···-•••••• ·- •• ---.~~-· ··.·-~---' ·-~--. • •• • •• <" ~---
· FUI1br:r AffiaDt sayeth ~. 

•;'.' 

··. ' .. 

, .. -~:: 

.. · .. 

. - -- -.;... . -.r.:· . ~- ..... 

AlliN M MEERlA 

lly CommiSSion ExPir8S 

June 1; 2018 

•'· ···~'·•·· •"•'-.~ ~ , ......... ·~ ••. ' .~ ···• .• •~.· ••• ·~·:.•----· t· ··""···•···. ~- •••. ,.·, ·~,.-...·r .. :,· ~ .• ,.~ 

2 

·,.~y ,/ 

IRSHAD ISMAIL BAIG 

Date: 

;l,., :. 
a,. .. ~ • 

~-- ·-. ·T.'. 

( 

STATE OF TEXAS 

V. 

IRSHAD ISMAIL BAIG, 

Defendant, Pro Se 

No. 15-CCR-180026 

County Court at Law No. 3 

Fort Bend County, Teus 

.1""1'" k~a\J,. Ar\ ' 

coP:S ~ ORIGINAL filed on "" 'y\:; 

in the fr\)ta1. records. 

Copies NO · compared. ':RA RIL:f, County Clerk 

AllFJJ)AVIT OF NffiJ.E PROSEOm 

I, UID IRBSAP BAIG. hereby and herein swear upon oath, under the penalty of perjury 

accordiilg to law that the following declarBtions, averments, stateDients of fact paragraphs l tbru 

5 are 1n1e, conect being based upon my personal knowiedge and experience. · 

1) I was bomDece.mberiB 1999 in the United Statesandamaniltural citizen thereot: I 

~Y ~de at 11706 Nobility Drive in Stafford, Texas 71477 and my present telephone 

number is 281-658-2640. 

2) I ·am the alleged Complainant in the above styled, numbered Cause of action due to erroneous 

state action(s) of Fort Bend CoUDty Offici8Js. At no time whatsoever did I ever~ request, 

seek ·or deSire to file any type of legal action against my natural father Irshad Ismail Baig 

during the year 2014 and to date. 

3) I was present, on the scenewi1Dess to all confrontation episodes over financial issues 

between my Mother Kausar Baig and ~ather Irsbad Baig during November2014 and at no 

time was there any actual, physi'* or emotional iDjmy suffered by my own person as a result 

oflrshad Ismail Baig's actions or omission of action. · 

4) On or about November 20, 2014 both my mother Kausar and myself were questioned by 

S1ate C.P.S. officer Enrico Fernando duriDg which time my stateinents were tape recorded. At 

those 1imes I specifically declared "I am not scared or afraid of my fatber Jrsbad." 

-

5) Based upon my own personal experience in the subject matter under C8use No.180026 I 

cannot see any rational cause for my father lrsbad to be .prosecuted for something he simply 

did not do. FurthermOre, it is repulsive to my mind to wimess a State Agency twist filets 

around to make appearances that simply do not exist, such as the charged Information saying 

· "did then and 1he.te intentionally, knowingly, or recklessly guse bodily inlm tO Zaid Baic 

.·.,.•,..,,,t·· ···-·.•~ ... _ ...•. :-..;:1:"'·'-" ... ·~·· -.·:'' ..... -...,,.,,, •• ,, ··.·:~ •• :~··'""·:.····~; ... ·, :, .. ·.·~.-.:. ·' , ••• ·-:··: .. ·.: •. ·.:.'.·.:. ... ~ 
.. ... . 

by pushing him with defendants hand." I hereby specifically declare nobody, including hsbad 

Ismail Baig. ever~ me any bodily injmy as fraudulently expressed·and charged by State 

· officials in Cause No. 180026 supra. · 

Sworn to and Subscn~ 

Before me on this l~y 

of Apri12015 

AMIN M.MEERZA 

My Commission Expires 

June 1; 2016 

Date: 

~·~ . 

· ZAIDBAIG 
' ' 

STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

No. 14-CCR-177950 

Coaaty Court at Law No. 3 

Fort Bead County, Taas · 

) 

) IN 1HE COUNTY COURT AT LAW 

) N0.3 

) 

) FOR 

) 

) 

. Defendant. Pro Se ) FORT BEND COUNTY, TEXAS 

) 

) 

AF'J'IDAVIT OJi' NOLLE PROSEQUI 

I, KAUSAR IRSHAD BAIG. do solemnly swear, aver, declare upon oath, under penalty of 

peajury, apcOrding to Jaw that the .following two par&&nlphs are true and correct based upon my 

own perscmal knowledge and experience. 

1) Tbe only reason I ever signed any type paper work or documeDt related to Fort Bend County, 

Texas Misdemeanor Cause Number 14-CCR-177950 was because I was placed in serious fear of 

losing parental custody over my children due to open threat by State of Texas employees 

intervi~ and questioniDg me about a fiunily incident. 

2) I do not intend to prosecUte, neither will I participate in any future comt or State sponsored 

activity related .to Fort Bend County, Texas Cause Number 14-CCR-177950. 

Further Affiant sayeth not. 

RECEIVED 

APR 20 2015 

KA IRSHAD BAIG 

11706 Nobility Drive 

Stafford, TX 77477 

DISTRJCT ATTDRNEY'S OFFICE Phone: + 1 281 6582640 

I • ·,I I 

. I 

•' 'I 

:.- ;J·· . . 

~ - • •• . ... . ••. ~- ... ,-,'1.), • • • 

. COPY 

ORIGINAL filed on ~ - ao - J 5 

in the ro ( a a records •. 

·Copies NOT compared'! . 

LAURA R~R~ COunty Clerk 

By. . . 
n-... J ... \\.1 ,_ ' 

No. 15-CCR-180026 

County Court at Law No. 3 

Fort Bend County, Texas 

) 

15-CCR-180026 

MOTI 

Motion (No Fee) 

3680737 

Ill 

) BEFORE THE COUNTY 

) COURT AT LAW NO. 3 

) 

) FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

setting forth the Court reasons for not grant 

Corpus relief prior to actual jury trial on subject 

CAUSE: 

1) On or about May 13,2015 Defendant filed his p 

Corpus Art. 11.04, 11.09 Tex. Code Crim. Proc. (20 1 0) 

2) 

disposition before the Court instanter. 

3) On or about June 30,2015, some 45 plus days beyond filing date ofsu · 

habeas corpus Application, the Court consolidated this Cause number with prePage 1 of2 

Ill 
... 

existing cause number 14-CCR-177950 and summarily scheduled jury trial of both 

21 5\2015. Cause number 14-CCR-177950 also has an unanswered Art. 

habeas corpus filed on or aboutApril23, 2015. 

p 

leadings summarily continuing to jury trial then Defendant's 

n I rights of meaningful access to courts; access to the Great 

e injury, compelling Defendant to develop and file 

PREMISES CONSIDERE 

5) 

States requires. So Moved, Prayed. 

MOTION GRANTED/DENIED: 

. Presiding Judge 

Fort Bend County, Texas 

Date: _____ ,2015 

Page 2 of2 

address and dispose of 

. 1.04; 11.09) before July 21, 

SM~~IG, pro-se 

: ~L-/ ,2015 

lt'~ ... -..-j 

~ r 
No. 15- CCR-180026 

County Court At Law No.3 

Fort Bend County, Texas 

) 

STATE OF TEXAS ) COUNTY COURT AT LAW . ) 

v. ) 

) No.3 

IRSHAD ISMAIL BAIG, ) 

) 

Defendant, Pro Se ) FORT BEND COUNTY, TEXAS 

) 

) 

CERTIFICATE OF SERVICE 

I, IRSHAD ISMAIL BAIG, hereby certify I have delivered a true, correct copy of 

foregoing, attached Motion: 

(1) Defendant's ProSe Motion to Withdraw Subject Matter Habeas Corpus Jurisdiction 

and Proceed Original Action in Texas Court of Criminal Appeals in Austin, Texas 

To: 

a) Fort Bend County Clerk Office 

b) Fort Bend County District Attorney Office 

c) Fort Bend County Attorney Office 

IRSHAD ISMAIL BAIG 

1 
STATE OF TEXAS 

v. 

IRSHAD ISMAIL BAIG, 

Defendant, ProSe 

No.lS-CCR-1180026 

County Court at Law No. 3 

Fort Bend County, Texas 

) 

) BEFORE THE COUNTY 

) COURTATLAWNO. 3 

) 

) FOR 

) 

) 

) FORT BEND COUNTY, TEXAS 

) 

) 

DEFENDANT PROSE MOTION TO WITHDRAW SUBJECT MATTER HABEAS 

CORPUS JlJRISDICTION AND PROCEED ORIGINAL ACTION IN TEXAS COURT 

OFCRIMINALAPPEALS,AUSTIN, TEXAS 

TO THE HONORABLE JUDGE OF SAID COURT: 

Comes now IRSHAD ISMAil.., BAIG, pro-se Defendant in Cause sub judice and 

hereby, herein NOlliiES the Court of Defendant's intent to withdraw all subject matter 

Habeas Corpus jurisdiction in above styled, numbered cause of action; thereafter, to file said 

subject matter Habeas Corpus as Original action in Texas Court of Criminal Appeals sua 

sponte. 

CAUSE: 

1) This habeas corpus action is a pre-trial action of which Defendant enjoys Texas and 

Federal RlGHf/ENTI1LEMENT to have the Court(s) rule, decide, and address the 

merits thereof. 

2) The instant Court has been sitting 6n top of Defendant's pro-se pre-trial habeas corpus 

pleadings over 115 days with<;mt addressing the facts set forth therein or transferring 

Page 1 of2 
said habeas corpus APPLICATION to the Texas Court of Criminal Appeals as 

required by law. 

3) The instant Court, to exacerbate the Defendant's Constitutional Right injury has also 

scheduled this Cause of action for jury trial on at least two prior occasions and then 

reset the Cause for trial on future dates. 

4) It strongly appears to be a formidable abuse of discretion on the Court's behalf toward 

Defendant, therefore Defendant withdraws said habeas pleadings in favor of 

proceeding Original action jurisdiction in Texas Court of Criminal Appeals. 

It is so urged, moved, and decreed by Defendant this lOth day of September 2015. 

Sworn and Subscribed 

before me thi~D. day 

ofS~ 

Notary Public for 

Fort Bend County, Texas 

KAVITA BHATT 

Notary Public 

STATE OF TEXAS 

My eomm. Exp. _11-13-18 

Pagel of2 

IRSHAD ISMAIL BAIG 

11706 Nobility Drive 

Stafford, TX 77477