# 0&fQ

EX PARTE

ABEL MEDRANO NO. IN THE COURT OF CRIMINAL APPEALS AUSTIN, TEXAS 

# saf\m-o\ COURTOFCRIMINALAPPEALS

,APR092015 AtelAcosta,Clerk

§ ORIGINATING INTHE 27th § DISTRICT COURT INAND FOR § LAMPSAS COUNTY, TEXAS

MOTION TO STAY PROCEEDINGS

TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS: 

### COMESNOW, Abel Medrano, Texas Department of Criminal justice (TDCJ)-ID #1743611, hereinafter "Movant" pro se in the above cap 

### tioned cause andmoves this Honorable Court to StayProceedings, 

### not for reason of delaybut, requestingdue process and offers this Honorable Court the following in support thereof:
Statement of the Case 

### OnJanuary28, 2015, Movant filedOriginal Application for Writ 

### of HabeasCorpus, §11.07, §11.073, with the district clerk of Lam pasas, Texas, Lampasas County, withMemorandum inSupport. On March 11, 2015, Movant's applicationwas receivedby this Court's Honorable Clerk and presented to this Court. On March 24, 2015, Movant received the Clerk's notice of same.On March 30, 2015, Movant sent correspondence to the district clerk requesting a copy of the State's Answer be forwarded immed iately. To date, Movant has not received a copy of the requested, nor 

### has he receivednotice that the State filedan answer inresponse to his application.
Due Process 

### Movant is requesting he be affordeddueprocess guaranteed to himby the Fourteenth Amendment to the United States Constitution and Article 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 informand forwardacopyof same, in violation of due process. Conclusion 

### Movant requests an opportunity to file'an objectionandrefute 

### any and all assertions and/or contentionsmade by the State and 

### contained intheiranswer inresponse tohisApplication for Writ of Habeas Corpus, §11.07, §11.073. Movant requests that the State be compelled to forwardMovant a copyof same, if one in fact has been filedwithhis application in this Court. Movant is entitled 

### to due process inthis proceeding andrequests an opportunityto file an objection, refuting anyand all assertions and/or conten 

### tions within the State's answer. Movant requests that the time frame to be reinstated toreflect the proper time tobeginthe date Movant receives the requested copyof the State's answer. Inthe 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 Hon orable Court to consider this Motion to StayProceedings, as moot 

### and to grant his application forWrit of Habeas Corpus, §11.07, §11.073. Prayer WHEREFORE, PREMISES CONSIDERED, Movant respectfully requests 

### this Honorable Court to consider Movant's Motion to StayProceed ings and to issue an Order this Honorable Court deems appropriate in this cause. So prayed. Respectfully.submitted,

>el Medrano #1743611 Dalhart Unit TDCJ 11950 FM 998 Dalhart, Texas 79022 Movant pro se Certificate of Service I, Abel Medrano, hereby certify that a true and correct copy 

### of the foregoing Motion to StayProceedings was filed on this the 3rd day of April, 2015, byplacing same in the Dalhart Unit's in 

### ternal mail system addressed to: LarryAllison, 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.Abel Medrano #1743611 Movant pro se
Unsworn Declaration I, Abel Medrano, TDCJ-ID #1743611, being presently incarcer 

### ated in the Dalhart Unit of the Texas Department of Criminal Justice in Hartley County, Texas, verify and declare under penal 

### tyof perjury, that the foregoing statements are true and correct 

### and that the original Motion to StayProceedings were placed in the Dalhart Unit's internal mailing systemon this the 3rdday of April, 2015.

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

ibel Medrano #1743611 Movant pro seEX PARTE

ABEL MEDRANO

On this, the 

### NO.
IN THE COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

ORIGINATING IN THE 27th DISTRICT COURT IN AND FOR LAMPASAS COUNTY, TEXAS

ORDER day of , 2015, came to be heard the Movant'.s Motion to StayProceedings and after having 

### reviewed the pleadings, heard the evidence, and the argument of Counsel, this Court is of the opinion that said Motion to Stay 

### Proceedings shouldbe: [ ]GRANTED [ ]DENIEDAS MOOT IT IS THEREFORE ORDERED that the Movant's Motion to Stay Pro 

### ceedings is GRANTED / DENIEDAS 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 PRESIDINGAbel Medrano #1743611 Dalhart Unit TDCJ 11950 FM 998 Dalhart, Texas 79022 April 03, 2015 Abel Acosta 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 withOrder Dear Clerk: Enclosed please find for filing Movant's Motion to Stay Proceed 

### ings withOrder. Please file date stampandbring to the attent ion of the Court. 

### Also enclosed, please find a copy of this letterhead. Please file date stamp same and return in the provided self addressed stamped envolpe. Thank' you for your assistance on this matter. Sincerely,

Abel Medrano. Movant pro se

AM/

cc: FILE LarryAllison, P.O. Box 1300, Lampasas, Texas 76550, Via U.S. 

### Postal Service, first class, postageprepaid. Enclosure: Original Motion to StayProceedings with Order, self addressed stamped envelope