Case Information
*1 PD-1119-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 10/14/2015 3:36:36 PM Accepted 10/15/2015 2:47:09 PM ABEL ACOSTA NO. PD-1119-15 CLERK STATE OF TEXAS § IN THE COURT OF
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vs. § CRIMINAL APPEALS
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PAUL ANTHONY GARCIA § AUSTIN, TEXAS
APPELLANT'S UNOPPOSED MOTION TO SET BOND TO THE HONORABLE JUDGE OF SAID COURT:
Now comes Paul Anthony Garcia, Appellant, and moves the Court to set bond in the above-referenced cause, and would show unto the Court the following:
1. On July 29, 2015, the Fourth Court of Appeals reversed Appellant’s conviction in the above-referenced cause and remanded the cause to the trial court for a new trial.
2. On August 28, 2015, the State filed a petition for discretionary to the Court of Criminal Appeals. Pursuant to Article 44.04 (h), Appellant is entitled to release on reasonable bail pending determination of the State’s petition for discretionary review . Pursuant to Article 44.04(h), since bail was requested after the State filed its petition for discretionary review, the Court of Criminal Appeals shall determine the amount of bail.
3. Appellant has conferred with the State concerning this issue. The State and Appellant concur that bail in the amount of $40,000.00 (the amount set by the trial court) would be a reasonable amount of bail in this cause.
4. Appellant respectfully requests that this Court set Appellant’s bail in this cause at $40,000.00, cash or surety, subject to any additional conditions of bail that may be set by the trial court.
WHEREFORE, PREMISES CONSIDERED , Appellant prays that the Court set a *2 reasonable bond herein in the amount of $40,000.00, cash or surety bond.
Respectfully Submitted,
M. Patrick Maguire, P.C.
Attorney and Counselor
945 Barnett Street
Kerrville, Texas 78028
Tel: (830) 895-2590
Fax: (830) 895-2594
By: /s/ M. Patrick Maguire
M. Patrick Maguire
State Bar No. 24002515
mpmlaw@ktc.com
Attorney for Paul Anthony Garcia CERTIFICATE OF SERVICE
This is to certify that on October 14, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Kendall County, 200 Earl Garrett, Suite 201, Kerrville, Texas 78028, by facsimile transmission to (830) 896-2620.
/s/ M. Patrick Maguire
M. Patrick Maguire