Court of Criminal Appeals Cause No. _______________________

IN THE 

COURT OF CRIMINAL APPEALS 

OF TEXAS

EX PARTE

ADAM REPOSA, 

APPLICANT

On a Judgement of Criminal Contempt 

in cause number C-1-CR-17-100018

in the County Court at Law No. 5

of Travis County, Texas

APPLICANT'S AMENDED EMERGENCY MOTION FOR STAY AND/OR 

MOTION FOR BOND PENDING THE FILING OF WRIT OF HABEAS 

CORPUS

Submitted by:

Carissa L. Beene

SBN: 24071967

215 W. University Avenue

Georgetown, TX 78626

512-850-0555

512-354-7416 (fax)

cbeene@defendtx.com

WR-86,973-03

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 10/6/2017 4:24 PM

Accepted 10/6/2017 4:31 PM

DEANA WILLIAMSON

CLERK

 RECEIVED COURT OF CRIMINAL APPEALS 10/6/2017 DEANA WILLIAMSON, CLERK 
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, Adam Reposa, Applicant, by and through Carissa L. Beene, his attorney 

of record, and files this Applicant's Emergency Motion for Stay and/or Motion for Bond Pending 

the Filing of Writ of Habeas Corpus, and would respectfully show the Court the following:

I.

Applicant, Adam Reposa, is an attorney licensed to practice law in the State of Texas. On 

September 11, 2017, Judge Paul Davis, sitting by assignment in Travis County as a contempt 

court, heard evidence on a contempt complaint against Applicant. On September 20, 2017, the 

contempt court issues findings of contempt and sentenced Applicant to six months incarceration, 

to commence on September 29, 2017. On motion of the Applicant the contempt court hearing 

stayed execution of the sentence until it could consider Applicant’s bond request on October 2, 

2017. The contempt court has now denied Applicant a personal or surety bond pending postconviction proceedings on the order of contempt and the sentence. Attached as Appendix A is a 

copy of the amended judgment of contempt.

II.

The State opposes this motion.

III.

Applicant intends to invoke this Court's original writ jurisdiction and file a writ of habeas 

corpus challenging the judgment of contempt made in the court below. Applicant believes that 

the judgment of contempt is void, Ex parte Amaya, 748 S.W.2d 224, 224 (Tex. 1988), and that 

subsequent punishment by Judge Davis is unlawful . However, Applicant is unable to file a writ 

of habeas corpus immediately because the record cannot be obtained immediately. Therefore, in 
order to maintain the status quo ante and to ensure that Applicant's request for relief is not 

rendered moot, Applicant respectfully requests that this Court, as it sees fit, either stay the 

execution of the judgment of contempt, set a bond for Mr. Reposa, or both pending the outcome 

of the writ proceedings. In the event that this Court sets a bond, Applicant also requests that this 

Court grant him release on personal bond, as an officer of the court. In the event that Applicant is 

not successful in ultimately obtaining relief, there will be time enough to serve his sentence at a 

later date.

WHEREFORE, PREMISES CONSIDERED, Applicant respectfully moves this court to 

stay the judgment of contempt in the court below and/or set a bond, and to grant personal bond 

pending future habeas proceedings.

Respectfully submitted, 

____________________________________ 

Carissa Beene

Attorney for Applicant

SBN: 24071967

215 W. University Ave. 

Georgetown, TX 78626

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Emergency Motion for Stay and/or 

Motion for Bond pending the filing of Writ of Habeas Corpus was served upon the attorney for 

the State on October 6, 2017.

____________________________________

Carissa Beene