RECEIVED IN
COURT OF CRIMINAL APPEALS
JUN 16 2015
·.._
Cause
Abel Acoota, Clall'k
2. Ex parte IN THE 19th JUDICIAL
DISTRICT COURT FOR
TgRRY GLENN HARRIS McLENNAN COUNTY,TEXAS
MOTION TO COMPEL HABEAS CORPUS
AD 'l'ESTIFICANDUM
5.
6. COMES NOW,T~RRY GELNN HARRIS,appli~ant in the above styled
7. and numbered cause,pursuant to tne interest of justice and brings
8. this MOTION TO COMPEL AD TESTIFICANDUM;· as per Article 11.31 of
9. Texas Code of Criminal Procedure ( CCP).
10. "'The person on whom the writ is served shall bring before
the JUdge the person in his custody,or under his restraint."
11~ Art.ll~3l,CCP of Texas.
' ' . .. ..
12. Ap~licant is currently in custody of the TDCJ,in ihe L.C.
13.· Powledge Unit,located i~ P~le~tiheiTex~s;in Anderson County; ap-
14. plicant 's TDCJ# is 1664009.
15. Applicant is requesting the Honorable Court to issue from
16. the bench, a warrant ordering the Sheriff of McLennan County to
17. transport said offender to the court issuing the warrant t6
18. participate in the hearing in this matter to give testimony.
19. Applicant contends that his presence is required because he
20. could aid counsel in his defense; the court should. base· their eva-
21. luation upon applicants demeanor, not relying on th·e-:sole testi-
22. many of trial counsel appointed by the court;the court should
23. grant the motion in the interest of Justice. Applicant contends
24. the case relies on his testimony rather than that of appointed
25. counsel for the defense.
Terry Harris-2010-544-ClA
MCADT-1 of 2
1. Applicant contends that his presence will serve the ends of
2. Justice by rel~aving the burden of appointing counsel on behalf
3. of the state; applicant contends his presence at the hearing
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c·-""'~4.
5.
would aid the court in finding common ground among the vast
evidence to his favor; applicant could aid in the cross exami-
6. nation ot witness for the prosecution; the court should hear the
7. applicant's own words and present appropriate rebuttal.
8. PRAYER
9. ·-
WHEREFORE PREMISES CONSIDERED, Applicant Terry Glenn Harris
10. respectfully prays that tnis Honorable Court will grant this
11. MOTION TO COMPEL HABEAS CORPUS AD TESTIFICANDUM and in all things
12. considered.
13. Rsepectfully submitted,
14.
Terry enn Harris,petitioner
15. #16640 9
1400 FM 3452,Powledge Unit
16. ~alestine,Texas 75803
17.
18. Executed on this~day of June,2015.
19.
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25.
Terry Harris-2010-544-ClA
MCADT-2 of 2
' '
In re: Cause 2010-544-ClA,Ex parte Harris-19th Judicial District
To ~he clerk of· the Court:
Please find enclosed the following WRIT OF HABEAS CORPUS AD TES-
TIFICANDUM to be~filed in the above named court and under the
cause number~listed .
- .. Thank you for your attention to matter and know that ytiur time is
greatly appreciated.
cc:fiJ.e
Terry G enn Harris,l664009
1400 FM 3452,Powledge Unit.
Palestine,Texas /5803