WR-83,797-01,02
W5
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/28/2015 2:59:37 PM
Accepted 8/28/2015 3:57:24 PM
ABEL ACOSTA
DOCKET NO. __________ CLERK
IN THE RECEIVED
COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS
8/28/2015
AT AUSTIN, TEXAS 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:
1. 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.
2. 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
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