A. PLGINTIFES ORIGINAL APPLICATION FOR WRIT OF MANDAMUS

TO THE HONORABLE JUDGE(s) OF SAID COURT: COMES NON. ANTHENY CASTELLEN, RELATOR, PRD SE IN THE ABOVE NUMBERED CAUSE AND FILES THIS ORIGINAL APPLICATION FOR WRIT OF MANDAMUS, PURELAMY TO TX. RULES, APP. PRE. 23.2 (A), (A), AND S HOW'S THIS COURT THE FOLLOWING:

B. RELATER

I.

ANTHONY CASTELLEN T.D.C. 1938649 is AN OFFENDER INCARCRRATED IN THE T.D.C. 5 AND is APPERRING. PRD. SE, WHO CAN BE LOCATED AT GROOMAN UNIT 344 PAIVATE RD. 943D. JASPER, TX 75951, THE RELATOR HAS EXHAUSTED HIS REMERGES AND HAS NO CTHER ADEQUATE REMEDY AT LAM. THE ACT SOLICITY TO BE COMPELLED is A JUDICIAL ONE, HOWEVER, RELATOR HAS A CLEAR RIGHT TO THE RELIGF SOLICIT 4 SEE SIMON US LEVANDS 306 S. 1 SU at 321 (D. CIIN. AM. 2009): Also, MIRSUMNT TO TEXAS RULES OF APPLLATE PRDICOURE RULE 23.2 "WHEN SENTENKE IS PROMOUNCED THE TRIAL COURT MOT Give the DEPENDENT CREDIT ON THAT SENTENCE FOR: (A) ALL TIME THE DEPENDENT HAS BEEN CONFIICED. SINCE THE TIME JUDGMENT AND SENTENCE STRULD HAVE BEEN ENTERED AND PROMOUNCED, AND (A), ALL TIME BETWEEN THE DEPENDANTS DEREST AND CONFIIGENENT TO THE TIME WHEN JUDGMENT AND SENTENCE STRULD HAVE BEEN ENTERED AND PRO- MOUNCED AMINAL by HOS 9-1-2010. THE RESPONDENT HAD A MINISTERIAL AND JUDICIAL DUTY TO GRANT RELATOR PROVIOUSLY REGUESTED JALL-time CREDITS AMINANT TO RULE 23.2 (A), (A) OF TEXAS RULES OF APPLLATE PROCEDURE.

II.

C. RESPONDENT.

RESPONDENGENT HON JUDGE KAYCEE L. JONES IN HER OFFICIAL CARACITY AS DISTRICT JUDGE OF Hill TUDICIAL DISTRICT CAURT OF TRIALITY, COUNITY TV HAS A JUDICIAL DUTY

*4 To ensure relative is created asil time ckedits He's entite to, in that the Law He in vokes is definite, urababies, and unquestionabey applies to the Indisputable facts of this case as prosciated by Texas rules of abeclate prob. CELURE RULE 23.2 (A), (B) a sec SiDAL vs. LEVABED 304 s.w. 3 d Af. 321 (TU.CR. MP. 2004). D. Volation of Rule 23.2 (A), (B) Texas Rules of Abelate Reccoune

Respondent Has violated Rule 23.2 (A), (B) of the Texas rules of abeelate proced ure by failing to ckans relative fail time ckedits for the time periods of reRuges le, down to areil 14.2014, In which He was Confined in TELLS COUNTS, TX., The Jurisdiction of Respondent, with feedback 4.2014 below regional are of RELATOR, RELATR SOLLIT RELIGF IN A "MUCK PRO TUBE MOTION" That was related by Respondent on deeember 14.2014, Without CITING ANY LECAL RECEeDENT, CASE LAW, OR OTHERWISE THE RESPONDENT REASON'S FOR REEUSING TO CRAST SAND SAIL time CREDIT WAS, RELATOR "PLED CHiCITY ON TIIY 1.2014 TO THE EFFENSE OF PROHIGITED SUBSTANCE IN A CORRECTIONAL FACTITY WITH OCLUYED ADEIL 14.2014, RELATOR is NOT ENTITLED TO ANY TAI CREDIT PERCE TO THE DATE OF THE EFFENSE FOR WHICH DEFENDANT WAS CONVILTEO". FOR SAND REASON'S RESPONDENT DEVIED RELIGF. Thus, "WHEN PETITION FOR WATS OF MANOAMUS is MADE. IT'S THE RELATORS ByROOK TO SHOY ENTITLEMENT TO THE RELIGF BEING REPRESEN, see IN RE DAVESOUL-IS3 s. W. 3 d Af 491 (TU. MP. 2004) 100001, In LIGHT OF THIS RELATOR MAINTAINS THAT THE LAW CLERALY STATES IN RULE 23.2 OF TEXAS RULES OF ABEELLATE PROCEDURE" WHEN SENTENCE IS PREMONATED THE TRIAL COUNST MUST GIVE THE DEFENDANT CREDIT ON THAT SENTENCE FOR (A) ALL TIME THE DEFENDANT HAS BEEN CONFICIED SINCE THE TIME TUDDMENT AND SENTENCE SHOULD HAVE BEEN EN TEREO AND PROMEQUICED, ANO (B). ALL TIME REPLUGED THE DEFENDANTS BECEST AND CONFICIEMENT TO THE TIME WHEN TUDDMENT AND SENTENCE SHOULD HAVE BEEN ENTEREO AND PROMEQUICED"MANUED BY ACTS 9-1-2014, Thus, THE RESPONDENTS RULNG ON SAND "MUCK PRO TUBE MOTION" is WYONC, THE RELATOR is (Pursuant to

*5 Aule 23.2 (A), (B) at arar.ro), entitled to time ceEot exuOR to the date of the offense for which He was conuisted, also. pursuant to the Precedent of teXas rules of Apellate PecEQuiel Aule 23.2 (A), (B), the RELATOR Has a "Clear RICHt to RELief" of Requested Jail time ceEot, the LAW He's INVoking is "definite, unAMRICUous AN UN QUESTIONABuy AMPIES To THE INDisputable Facts of His Case" $\to$ see Simonly LeVareco-300 sim. 30 ar 30 (TA. CRim. Apr. 2001). Thus, the Respondent Has Violated, Texas rules of Apellate Proceoune Rule 23.2 (A), (B). D.

PRAYER FOR RELief WHEREFORE, PREMIXES CONSIDERED THE RELATOR PRAYS THIS COURT GRANT THIS ORIGINAL APPLICATION FOR WRIT OF MANOMMUS ANO ORDER THE RESPONDENT TO GRANT His REqUESTED Jail time CREQIT, He's EUTITED TO, By OPERATION of LAW INCOMPARATED IN TENAS RULES OF APPEIIATE PROCEDURE. 50 MOVED AND PRAYED THAT THIS ORICING APPLICATION FOR WRIT OF MANOMMUS BE GRANTED. EXECUTED, THIS NOT ANY OF FEDUASY, 2001.

E.

UNISMORN DECLARATION I. Aythony Costullon 1968/99 do thereby state under PENNILTY OF PERTURY, THAT ALL INFOR MATION CONTINUED HEREIN THIS SAID APPLICATION FOR WRIT OF MANOMMUS, Is THEE AND CORRECT TO THE BEST OF MY KNOWLEDGE.

*6 F. GERTIFICATE OF SERVICE T. Anthony Coddling 1238019 . DO HEREBY CERTIFY THAT A TRUE ANO COMEECT COPY OF THE ABOVE AMIGRATION FOR WRIT OF MANOAMUS HAS BEEN SERVED TO CATHY S. LUSK-CLEAK OF THE TWELFTH COURT OF APPERALS AT 1517 W. FRONT ST STER 254 TYLER. TX 75702, ON THIS L74R DAY OF JANUARTA 2015. BY PLACINC-54ME IN THE COOMMAN-4WIT MAILRCM. TIO CTR MILT DETE 1835619.