HOLGUIN, CANDELARIO Jr.

WR-67 ,454-08 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 6/24/2015 5:34:05 PM Accepted 6/25/2015 8:16:29 AM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK FOR THE STATE OF TEXAS AUSTIN, TEXAS RECEIVED COURT OF CRIMINAL APPEALS 6/25/2015 ABELACOSTA,CLERK EXPARTE § § § NOS. WR-67,454-07 § WR-67,454-08 CANDELARIO HOLGUIN, JR. §. WR-67 ,454-09 AGREED MOTION TO RETURN APPLICATIONS FOR WRITS OF HABEAS CORPUS TO DISTRICT COURT TO THE HONORABLE COURT OF CRIMINAL APPEALS: NOW COMES CANDELARIO HOLGUIN, JR., Applicant, and respectfully asks this. Court to return the above styled and numbered applications for writs of habeas corpus to the District Court for an evidentiary hearing and would show the Court the following: I. The writ applications filed by Candelario Holguin, Jr. in the Criminal District Court of Dallas County were received by this Court on June 22, 2015. They were assigned numbers WR-67,454-07, WR-67,454-08, and WR-67,454-09. II. An evidentiary hearing is scheduled in the trial court on Applicant's writ Agreed Motion to Return Applications for Writs of Habeas Corpus to District Co~~W,CJJf_?JrJyNJIC .UC(Q)m.D ..-. ./ . ~ ..~ : . applications for September 18, 2015. This is the earliest date available for the hearing based on the availability of the witnesses necessary to resolve the issues in Applicant's writ applications. III. An evidentiary hearing is necessary to properly resolve the issues raised in the writ applications. These writ applications should therefore be returned to the trial court for further factual development at the evidentiary hearing ·on September 18, 2015. FOR THE ABOVE REASONS, Applicant respectfully asks that this agreed motion be granted. Respectfully submitted, /s/ Robert N: Udashen ROBERT N. UDASHEN, P.C. Bar Card No. 20369600 SORRELS, UDASHEN & ANTON 2311 Cedar Springs Road Suite 250 Dallas, Texas 75201 214-468-8100 214-468-8104 (fax) Attorney for Applicant AGREED: /s/ Laura Coats Laura Coats Assistant District Attorney Agreed Motion to Return Applications for Writs of Habeas Corpus to District Court - Page 2