*1 DOCKET NO.
IN THE COURT OF CRIMINAL APPEALS AT AUSTIN, TEXAS
RECEIVED COURT OF CRIMINAL APPEALS 8/28/2015 ABEL ACOSTA, CLERK
IN RE: DARRELL CURLEE, Relator
MOTION FOR LEAVE TO FILE PETITION FOR WRIT OF MANDAMUS AND WRIT OF PROHIBITION
TO THE HONORABLE COURT OF CRIMINAL APPEALS: Darrell Curlee, Relator, moves this Court to grant him leave to file his Petition for Writ of Mandamus and Writ of Prohibition, and shows:
- 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.
- 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 tacitly removing appointed counsel on a whim,
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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/ Terence Russell Terence A. "Tiger" Russell S.B.O.T. #17437070
1040 E. Elm St. Hillsboro, Texas 76645 Tel: (254) 580-9282 Fax: (254) 582-5593 tiger_russell@att.net Attorney for Relator, Darrell Curlee L.T. "Butch" Bradt #02841600
14015 Southwest Freeway, Suite 4 Sugar Land, Texas 77478 (281) 201-0700
Fax: (281) 201-1202 ltbradt@flash.net
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:
RESPONDENT: Honorable A. Lee Harris
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66th Judicial District Court PO Box 284 Hill County Courthouse Hillsboro, Texas 76645 (254) 582-4045
STATE:
Mark Pratt, District Attorney PO Box 400 Hill County Courthouse Hillsboro, Texas 76645 Phone: (254) 582-4070 Fax: (254) 582-4036 ADDITIONAL COUNSEL: Lyle Vincent Gripp 100 N 6th St., Suite 703 Waco, TX 76701 254-756-1112 On August 28, 2015. /s/ Terence Russell Terence A. "Tiger" Russell