Case Information

*0 RECEIVED COURT OF CRIMINAL APPEALS 6/25/2015 ABEL ACOSTA, CLERK *1 WR-67,454-09 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 6/24/2015 5:35:47 PM Accepted 6/25/2015 8:16:37 AM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK FOR THE STATE OF TEXAS

AUSTIN, TEXAS

EX PARTE §

§

§ NOS. WR-67,454-07 § WR-67,454-08 CANDELARIO HOLGUIN, JR. § WR-67,454-09

AGREED MOTION TO RETURN

APPLICATIONS FOR WRITS OF HABEAS CORPUS

TO DISTRICT COURT

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

NOW COMES CANDELARIO HOLGUIN, JR., Applicant, and respectfully

asks this Court to return the above styled and numbered applications for writs of

habeas corpus to the District Court for an evidentiary hearing and would show the

Court the following:

I.

The writ applications filed by Candelario Holguin, Jr. in the Criminal District

Court of Dallas County were received by this Court on June 22, 2015. They were

assigned numbers WR-67,454-07, WR-67,454-08, and WR-67,454-09.

II.

An evidentiary hearing is scheduled in the trial court on Applicant’s writ

Agreed Motion to Return Applications for Writs of Habeas Corpus to District Court - Page 1

applications for September 18, 2015. This is the earliest date available for the hearing

based on the availability of the witnesses necessary to resolve the issues in

Applicant’s writ applications.

III.

An evidentiary hearing is necessary to properly resolve the issues raised in the

writ applications. These writ applications should therefore be returned to the trial

court for further factual development at the evidentiary hearing on September 18,

2015.

FOR THE ABOVE REASONS, Applicant respectfully asks that this agreed

motion be granted.

Respectfully submitted,

/s/ Robert N. Udashen ROBERT N. UDASHEN, P.C. Bar Card No. 20369600 SORRELS, UDASHEN & ANTON 2311 Cedar Springs Road Suite 250

Dallas, Texas 75201

214-468-8100

214-468-8104 (fax)

Attorney for Applicant

AGREED:

/s/ Laura Coats

Laura Coats

Assistant District Attorney

Agreed Motion to Return Applications for Writs of Habeas Corpus to District Court - Page 2