Rafael Hernandez-Prado v. State

ACCEPTED 03-15-00289-CR 7177117 THIRD COURT OF APPEALS AUSTIN, TEXAS 9/30/2015 7:41:51 PM JEFFREY D. KYLE CLERK NO. 03-15-00289-CR FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 9/30/2015 7:41:51 PM FOR THE JEFFREY D. KYLE THIRD SUPREME JUDICIAL DISTRICT Clerk AT AUSTIN, TEXAS RAFAEL HERNANDEZ-PRADO, Appellant vs. THE STATE OF TEXAS, Appellee Appeal from the 33rd Judicial District Court Cause No. 9767 Burnet County, Texas The Honorable J. Allan Garrett, Judge Presiding APPELLANT'S MOTION TO ABATE Gary E. Prust State Bar No. 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com ATTORNEY FOR APPELLANT Motion to Abate Page 1 of 4 Hernandez-Prado v. State Appellate Cause No. 03-15-00289-CR ORAL ARGUMENT IS NOT REQUESTED APPELLANT’S MOTION TO ABATE Appellant, Rafael Hernandez-Prado, files this, his “Motion to Abate,” and in support thereof shows as follows. I. 1. Appellant appeals from an order adjudicating his guilt and a sentence imposing 15 years confinement. 2. Concurrent with this appeal, Appellant filed an appeal from a denial of his application for writ of habeas corpus filed pursuant to TEX. CODE CRIM. PROC. art. 11.072 (West 2015). In the trial court proceedings, Appellant’s application for a writ of habeas corpus and the State’s request to adjudicate were heard at the same time. IV RR 15. 3. Appellant has filed on September 30, 2015 a motion to abate with this Court in the appeal of the companion case regarding the application for writ of habeas corpus. In that motion, Appellant requested the Appellate Court direct the trial court to enter written findings of fact and conclusions of law. 4. Appellant’s motion to abate, if granted, and will be beneficial, if not necessary, to adequately address the issues raised in this appeal. 6. Accordingly, Appellant request that this Court abate this appeal along with Motion to Abate Page 2 of 4 Hernandez-Prado v. State Appellate Cause No. 03-15-00289-CR the appeal in cause number 03-15-00290-CR for the submission of findings of fact and conclusions of law. Respectfully submitted, /s/ Gary Prust Gary E. Prust SBN 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com Attorney for Appellant Motion to Abate Page 3 of 4 Hernandez-Prado v. State Appellate Cause No. 03-15-00289-CR CERTIFICATE OF SERVICE In compliance with Rule 9.5(d) of the Texas Rules of Appellate Procedure, the undersigned attorney certifies that a true and correct copy of the foregoing Motion was served Mr. Gary Bunyard of the 33rd and 424th District Attorney’s Office via electronic service through efile.txcourts.gov on this 30th day of September 2015. /s/ Gary E Prust Gary E. Prust CERTIFICATE OF CONFERENCE In compliance with Rule 10.1(a)(5) of the Texas Rules of Appellate Procedure, the undersigned attorney certifies he conferred with Mr. Gary Bunyard of the 33rd and 424th District Attorney’s Office on this 30th day of September 2015, and opposing counsel neither joins nor opposes this motion. /s/ Gary Prust Gary E. Prust CERTIFICATE OF COMPLIANCE Pursuant to TEX. R. APP. PROC. 9.4(i)(3), I hereby certify this brief contains 196 words. This is a computer-generated document created in Microsoft word, using 14-point typeface. In making this this certificate, I rely on the word county provided by the software use to prepare the document. /s/ Gary Prust Gary E. Prust Motion to Abate Page 4 of 4 Hernandez-Prado v. State Appellate Cause No. 03-15-00289-CR