Case Information

*0 RECEIVED COURT OF CRIMINAL APPEALS 5/15/2015 ABEL ACOSTA, CLERK *1 DOCKET NO. __________ IN THE

COURT OF CRIMINAL APPEALS AT AUSTIN, TEXAS

IN RE:

BRANDON JAY CARTER, Relator

MOTION FOR LEAVE TO FILE PETITION FOR WRIT OF MANDAMUS AND WRIT OF PROHIBITION TO THE HONORABLE COURT OF CRIMINAL APPEALS:

Brandon Jay Carter, Relator, moves this Court to grant him leave to file his Petition for Writ of Mandamus and Writ of Prohibition, and shows:

1. Concomitantly with filing of this Motion, Relator is tendering to the Clerk of the Court his Petition for Writ of Mandamus and Writ of

Prohibition. That Petition is incorporated into this Motion, by reference, for

all intents and purposes, as though set forth herein verbatim.

2. Relator represents that his Petition for Writ of Mandamus presents an issue of great importance which may be paraphrased as follows:

may a judge ignore a defendant’s Due Process rights and this Court’s

pronouncements of law by removing appointed counsel on a whim, without

a hearing.

3. Relator suggests that this issue is of great importance, not only to him, but to the criminal jurisprudence of Texas.

4. Relator therefore prays that this Honorable Court grant him leave to file his Petition for Writ of Mandamus and Writ of Prohibition. Relator

prays for general relief.

Respectfully submitted, /s/ D. Chris Hesse David Christopher Hesse S.B.O.T. # 24049081 112 West 8th Avenue, Suite 301 Amarillo, Texas 79101 Tel: (806) 350-6785 Fax: (806) 350-6786 Chris@PanhandleCriminalDefense.Attorney Attorney for Relator, Brandon Jay Carter Of Counsel:

L.T. “Butch” Bradt #02841600

14015 Southwest Freeway, Suite 4

Sugar Land, Texas 77478

(281) 201-0700

Fax: (281) 201-1202

ltbradt@flash.net

Michael Mowla #24048680

445 E. FM 1382 #3-718

Cedar Hill, Texas 75104

(972) 795-2401

michael@mowlalaw.com

CERTIFICATE OF SERVICE I, the undersigned attorney, in accordance with the Rule 9.5, T.R.A.P., certify that a true and correct copy of the foregoing Petition was delivered to:

Honorable Thomas R. Culver, III

240 TH Judicial District Court

Fort Bend County Justice Center

1422 Eugene Heimann Circle

Courtroom: Room 3E

Richmond, Texas 77469

Becky.Fisher@fortbendcountytx.gov

John F. Healey, Jr., District Attorney

Gail Kikawa McConnell, Ass’t District Attorney

1422 Eugene Heimann Circle

Richmond, TX 77469

Gail.McConnell@fortbendcountytx.gov

Harris S. Wood, Jr.

701 North Post Oak Road #425

Houston, Texas 77024

hwoodatty@yahoo.com

On May 11, 2015.

/s/ D. Chris Hesse D. Chris Hesse