Request,Application: The State of Texas VS. MARTIN JACKSON

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Preview
                                Electronically Filed
                                                                               6/6/2024 9:07 AM
                                                                               Hidalgo County District Clerks
                                                                               Reviewed By: Armando Cantu

                                           C-2650-24-A
                                 CAUSE NO. ______________

 STATE OF TEXAS                                §     IN THE DISTRICT COURT
                                               §
 vs.                                           §     _____JUDICIAL DISTRICT
                                               §
 MARTIN JACKSON                                §     HIDALGO COUNTY, TEXAS
 D.O.B: 03/28/1986
 PID: 848649

   APPLICATION FOR WRIT OF HABEAS CORPUS SEEKING BAIL REDUCTION

TO THE HONORABLE JUDGE OF SAID COURT:

       Now comes MARTIN JACKSON, Defendant, by and through attorney of record, and

makes this Application for Writ of Habeas Corpus Seeking Bail Reduction, and for good cause

shows the following:

       1.        MARTIN JACKSON is illegally confined and restrained of liberty by the Sheriff

of HIDALGO County, Texas in the HIDALGO County Jail in EDINBURG, Texas in lieu of a

bond in the amount of $15,000.00. MARTIN JACKSON is charged with

(a) POSS CS PG 1/1-B>-=1G<4G

       2.        MARTIN JACKSON confinement and restraint is illegal because bond is

excessive, oppressive and beyond the financial means MARTIN JACKSON, 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.

       3.        MARTIN JACKSON respectfully requests this Court to conduct an evidentiary

hearing and, after receiving evidence, to reduce the amount of bond to a reasonable amount in

order that MARTIN JACKSON PO will have an opportunity to obtain release from incarceration

pending trial.
                                                                               Electronically Filed
                                                                               6/6/2024 9:07 AM
                                                                               Hidalgo County District Clerks
                                                                               Reviewed By: Armando Cantu
                                           C-2650-24-A



WHEREFORE, PREMISES CONSIDERED, MARTIN JACKSON prays that the Court grant

and issue a Writ of Habeas Corpus to the Sheriff of HIDALGO County of HIDALGO County,

Texas, directing and commanding production of MARTIN JACKSON before this court instanter

or at such time and place to be designated by this Court, then and there to show cause, if any

there be, why MARTIN JACKSON should not be discharged from such illegal confinement; or

that MARTIN JACKSON be allowed bail in a reasonable amount. MARTIN JACKSON further

prays that immediate bail be allowed in a reasonable amount conditioned Martin Jackson appear

at the hearing to await further orders of the Court.

                                              Respectfully submitted,

                                              PALACIOS LOVE LAW PLLC
                                              513 S. 10th Avenue
                                              Edinburg, Texas 78539
                                              Tel: (956) 287-0555
                                              Fax: (956) 287-0188




                                              By:
                                                    Patricia Palacios Love
                                                    State Bar No. 24048707
                                                    Email: palacioslovelaw@yahoo.com
                                                    Attorney for Defendant
                                                                                   Electronically Filed
                                                                                   6/6/2024 9:07 AM
                                                                                   Hidalgo County District Clerks
                                                                                   Reviewed By: Armando Cantu
                                          C-2650-24-A




                                CERTIFICATE OF SERVICE

       This is to certify that on this the 6th day of June, 2024, a true and correct copy of the

above and foregoing document was served by hand delivery on the following counsel of record:



       Hidalgo County District Attorney’s Office
       100 E. Cano
       Edinburg, Texas 78539
       Fax: (956) 318-2301
       Email:o rlando.esquivel@da.co.hidalgo.tx.us




                                             PATRICIA PALACIOS LOVE