*1 10 fahs THE STATE OF TENA S VS MATIN TEAML. GROSSAN
CAUSE NO. 2014-CR-0116 CAURT OF COMMNAL APPEALS OF TENA S P.O. BOX 12305, CAPITAL STATION "In The Wives of JUSTICE" COURT OF COMMNAL APPEALS BALL PENDING APPEAL NOV 052015
To the HONORABLE VIDE OF SALO COURT: Come now Mattew Canal Jackson, Additioner, who upon A.S. as P. 15. he is restrained of his liberty by the Court's refusal to admit him to bail pending the appeal of a judgment and sentence entered herein on the 8 day of October 1, 2015, and appeared to Court of Criminal Appeals of TEXAS P.O. BOX 12305, CAPITAL STATION HUSTIN, TEXAS POTIL ON the 9 days of October 1, 2015. Applicant would show the Court that such restraint of his liberty is illegal for the following reasons: 1. Article 4(2)(6)(c) of the Texas Code of Criminal Procedure provides: "Anding the appeal from any felony conviction... the trial court may... permit the defendant to remain at large or existing but, if not then or bail, admit him to a reasonable butentail his conviction becomes final..." 2. Although the decision to admit defendant to bail pending his appeal from a felony conviction is one which is which within the discretion of the trial court, the legislature has provided certain guideline and mandatory processes within which, that discretion must be exercised. The 94 are: "Oh "... the defendant may not be released or bail pending appeal from a felony conviction where the punishment Accels is your construction..." U.A.C.C.P., Article 4(2)(c)(d) "... the trial court may deny bail and commit defendant to custody if the there exists good cause to believe that the defendant would not appear when his conviction became final or is likely to commit another offense while or bail..." U.A.C.C.P., Article 4(2)(c)(e). 3. Additioner states that there is no good reason to believe that he would not appear upon final conviction or that he would commit another crime while or bail pending final conviction in this case. Additioner asserts he has been in Bose County Retention for 24 months or 830 , but would be able, he is unable to post Additioner has no prior of criminal history and is a senior of Grambling State University about to evaluate, Additioner was attested without a nacional illegality state fail andated speedy trial Act and petitioner was sentence to 7 years. Under Article 17.151 a defendant is entitled to release by reduction of bail, a criminal action commences for purposes of Article 32A02. HIPPLEPORE, MEMISSE'S CONSIDERED, Additioner prays that he be bought before this Announte Court restorer, and that he be released or bail pending appeal, or in the attendance, a learing be scheduled to hear evidence as to why he should or should not be released or bail pending appeal.
Reportfully submitted