Case Information

*1 No. 13-5-9030-A 39,192-19

In the Texas Court of Criminal Appetts at Austin, Texas

In Re Herman Lee Kindred, Relaton

Motion for leave to File ORIGINAL Application for Writ on Receives

JUL 17,205

To the Honorable Judges of Samuel Heffernan

comes now Herman Lee Kindred, Relaton in the instant Cause and perays the Court will grant his motion for leave to file the attached original application for writ of mandamus.

Respectfully submitted, Heman Lee Kindred

*2 No. 13-5-9030-4

IN THE TERMS COURT OF CRIMINAL ADEPENls

IN RE HERMAN LEE KINDRED, REIATOR

TNATION FOR LEAVE TO FILE CRIMINAL ADEPLICATION FOR WRIST OF MANOMANUS.

TO THE HONDRADE JUDges OF SAID COURT:

CONES NOW HERMAN LEE KINDRED, REIATOR. IN THE INSTANT CAUSE AND PEAUS THE COURT WILL gRANT his ORIGINAL ADEPLICATION FOR WRIST OF MANOMANUS AND WOULD SHOULD

THE TUNE 8TH 2015, DURSHANT TO TEX CRIM. PROC. CODE AØT. 11.07 REIATOR FILED ONE (1) DOST-CONVICYTION WRIST OF BABEAS CORPUS ADEPLICATION CHALLENGING, NONVICYTION IN THE STATE OF TERMS VIS. HERMAN LEE KINDRED. CAUSE # 13-5-9030, IN THE 24TH DISTRICT COURT OF JACKSON COUNTRY, TEX EDIA, TEX TEXST.

AS OF JULY 15, 2015, DURSHANT TO AØT 11.09 2015, THE TRIAL COURT has "Not" ENTERED AN ORGEN

*3

To designate the issues presented in the application in need of Resolution. "Neither" has the States Attorney Answered in mayday at all. "No Type of Response." There has "not" been any order directing trial counsel "william Allen White of Victoria, or to file an affidavit within 30 days of June 8th, 2015.

As of this date, no affidavit by trial counsel has been filed and the habeas corpus application is classified as "inactive" by the Jackson County District Clerk. The issues previously in need of Resolution Remain unresolved.

IV

applicant complains the Respondent, the Honorable Jack Marr presiding Judge of the 24th District Ceuer of Jackson County terms has violated two ministerial duties. First, Contreary to verb 11.07 more than 35 days have elapsed and the application have yet to be forwarded to this Ceuer. Second, Contreary to TEX.R. App 73.5 Respondent has failed to answer in anyway at all to people the issues in need of resolution within the 36 days of the June 8th

*4

2015 filing date of the 11.07 wait of Habess Corpus Respondent did "not" seek an extension at all, from this count at all. Heemans see Kanoed has no adequate Remedy at law in which to present the instant Complaint and is required to present to the vehicle of man- dome

PRAYER

Wheertore, premises considered, Relation Heemans see Kanoed press this count will grant leave to file and direct the Respondent trial. Judge to Resolve the issues set out in the application and then have the District Clerk Subnet the records on such application to this count.

Certificate of Service

I. Heeman see Kanoed, Relation, do hereby Cettity that a time and correct copy of the forelining document was mailed to Respondent the Monohable Jack man, Robert E. Bell, and Sharon mathis of the sufer, District count at: 115 West Main St. Edna, Texas 77957 Rom 203 on July 2015. 2015. Respectfully Submitted, Heeman see Kanoed