On March 27, 2024 a
Request,Application
was filed
involving a dispute between
The State Of Texas,
and
for Habeas Corpus
in the District Court of Hidalgo County.
Preview
Electronically Filed
3/27/2024 4:09 PM
Hidalgo County District Clerks
Reviewed By: J uan Galvan
C-1453-24-|
CAUSE NO.
STATE OF TEXAS § IN THE DISTRICT COURT
§
VS §
§ JUDICIAL DISTRICT
LARRY JEAN KOCH
SO: 437221 § HIDALGO COUNTY, TEXAS
APPLICATION FOR WRIT OF HABEAS CORPUS SEEKING BOND REDUCTION
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes, Attorney for Defendant, LARRY JEAN KOCH, and makes this
Application for Writ of Habeas Corpus Seeking bond reduction, and for good cause shows the
following:
1 LARRY JEAN KOCH was arrested on March 13, 2024 and is presently
confined in the Hidalgo County Jail by virtue of a complaint filed by the Hidalgo
County Sheriff's Office.
LARRY JEAN KOCH is illegally confined and retrained of liberty by the
Sheriff
of Hidalgo County, Texas in the Hidalgo County Jail in Edinburg, Texas.
LARRY JEAN KOCH is charged with:
Charg Warrant # Bond
CONTINUOUS VIOLENCE 2400748 $5,000.00 c/s
AGAINST FAMILY
ASSAULT CAUSES BODILY 2400738 $5,000.00 c/s
INJURY FAMILY MEMBER
CONTINUOUS VIOLENCE 2400737 $5,000.00 c/s
AGAINST FAMILY MEMBER
ASSAULT FAM/HOUSE MEM 2400749 $5,000.00 c/s
IMPEDE BREATH/CIRCULAT
3 LARRY JEAN KOCH’S confinement and restraint is illegal because LARRY JEAN
Electronically Filed
3/27/2024 4:09 PM
Hidalgo County District Clerks
Reviewed By: J uan Galvan
C-1453-24-1
KOCH has not been given a reasonable bond, in violation of the Eighth and Fourteenth
Amendments to the United States Constitution, Article I, §§ 11, 13 and 19 of the Texas
Constitution, and Articles 1.09 and 17.15 of the Texas Code of Criminal Procedure.
4 LARRY JEAN KOCH respectfully requests this Court set a reasonable bond so
that LARRY JEAN KOCH will have an opportunity to be released from incarceration.
WHEREFORE, PREMISES CONSIDERED, LARRY JEAN KOCH prays that the
Court grant and issue a Writ of Habeas Corpus to the Sheriff
of Hidalgo County, Texas, directing
and commanding production of LARRY JEAN KOCH before this court instanter, or at such time
and place to be designated by this Court LARRY JEAN KOCH. Further prays that immediate
bail be allowed in a reasonable amount, conditioned that LARRY JEAN KOCH Appear at all
future hearings.
Respectfully submitted,
Law Office of Richard D. Gonzales, P.C
814 Del Oro Lane
Pharr, Texas 78577
P: (956) 513-8011
E: richard@richardgonzaleslaw.com
By: Ext 64A—
Richard D. Gonzales
State Bar No. 24074290
Attorney for Defendant
Electronically Filed
3/27/2024 4:09 PM
Hidalgo County District Clerks
Reviewed By: J uan Galvan
C-1453-24-1
CERTIFICATE OF SERVICE
I certify that on the 27th day of March, 2024, a true and correct copy of APPLICATION FOR
WRIT OF HABEAS CORPUS SEEKING BOND REDUCTION was served to each person
listed below by the method indicated.
Eued 64—
Richard D. Gonzales
VIA E-FILE:
Orlando.esquivel@da.co.hidalgo.tx.us
lola@richardgonzaleslaw.com
richard@richardgonzaleslaw.com
Electronically Filed
3/27/2024 4:09 PM
Hidalgo County District Clerks
Reviewed By: J uan Galvan
C-1453-24-1
Document Filed Date
March 27, 2024
Case Filing Date
March 27, 2024
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Electronically Filed 3/27/2024 4:09 PM Hidalgo County District Clerks Reviewed By: J uan Galvan C-1453-24-| CAUSE NO. STATE OF TEXAS § IN THE DISTRICT COURT § VS § § JUDICIAL DISTRICT LARRY JEAN KOCH SO: 437221 § HIDALGO COUNTY, TEXAS APPLICATION FOR WRIT OF HABEAS CORPUS SEEKING BOND REDUCTION TO THE HONORABLE JUDGE OF SAID COURT: Now comes, Attorney for Defendant, LARRY JEAN KOCH, and makes this Application for Writ of Habeas Corpus Seeking bond reduction, and for good cause shows the following: 1 LARRY JEAN KOCH was arrested on March 13, 2024 and is presently confined in the Hidalgo County Jail by virtue of a complaint filed by the Hidalgo County Sheriff's Office. LARRY JEAN KOCH is illegally confined and retrained of liberty by the Sheriff of Hidalgo County, Texas in the Hidalgo County Jail in Edinburg, Texas. LARRY JEAN KOCH is charged with: Charg Warrant # Bond CONTINUOUS VIOLENCE 2400748 $5,000.00 c/s AGAINST FAMILY ASSAULT CAUSES BODILY 2400738 $5,000.00 c/s INJURY FAMILY MEMBER CONTINUOUS VIOLENCE 2400737 $5,000.00 c/s AGAINST FAMILY MEMBER ASSAULT FAM/HOUSE MEM 2400749 $5,000.00 c/s IMPEDE BREATH/CIRCULAT 3 LARRY JEAN KOCH’S confinement and restraint is illegal because LARRY JEAN Electronically Filed 3/27/2024 4:09 PM Hidalgo County District Clerks Reviewed By: J uan Galvan C-1453-24-1 KOCH has not been given a reasonable bond, in violation of the Eighth and Fourteenth Amendments to the United States Constitution, Article I, §§ 11, 13 and 19 of the Texas Constitution, and Articles 1.09 and 17.15 of the Texas Code of Criminal Procedure. 4 LARRY JEAN KOCH respectfully requests this Court set a reasonable bond so that LARRY JEAN KOCH will have an opportunity to be released from incarceration. WHEREFORE, PREMISES CONSIDERED, LARRY JEAN KOCH prays that the Court grant and issue a Writ of Habeas Corpus to the Sheriff of Hidalgo County, Texas, directing and commanding production of LARRY JEAN KOCH before this court instanter, or at such time and place to be designated by this Court LARRY JEAN KOCH. Further prays that immediate bail be allowed in a reasonable amount, conditioned that LARRY JEAN KOCH Appear at all future hearings. Respectfully submitted, Law Office of Richard D. Gonzales, P.C 814 Del Oro Lane Pharr, Texas 78577 P: (956) 513-8011 E: richard@richardgonzaleslaw.com By: Ext 64A— Richard D. Gonzales State Bar No. 24074290 Attorney for Defendant Electronically Filed 3/27/2024 4:09 PM Hidalgo County District Clerks Reviewed By: J uan Galvan C-1453-24-1 CERTIFICATE OF SERVICE I certify that on the 27th day of March, 2024, a true and correct copy of APPLICATION FOR WRIT OF HABEAS CORPUS SEEKING BOND REDUCTION was served to each person listed below by the method indicated. Eued 64— Richard D. Gonzales VIA E-FILE: Orlando.esquivel@da.co.hidalgo.tx.us lola@richardgonzaleslaw.com richard@richardgonzaleslaw.com Electronically Filed 3/27/2024 4:09 PM Hidalgo County District Clerks Reviewed By: J uan Galvan C-1453-24-1