Electronically Filed 7/6/2018 11:12 AM

Sarah Loucks, District Clerk

Bastrop County, Texas
By: Becky Nelson, Deputy
423-5826
NO.

STATE OF TEXAS § IN THE DISTRICT COURT

§
VS. § _____ JUDICIAL DISTRICT
§
TERRY NELSON § BASTROP COUNTY, TEXAS

APPLICATION FOR WRIT OF HABEAS CORPUS SEEKING PERSONAL

RECOGNIZANCE BOND

TO THE HONORABLE JUDGE OF SAID COURT:

Now comes, Terry Nelson, Defendant, by and through attorney of record, and makes this

Application for Writ of Habeas Corpus Seeking Personal Recognizance Bond, and for good cause

shows the following:

1. Defendant, is illegally confined and restrained of liberty by the Sheriff of Bastrop

County, Texas in the Bastrop County Jail in Bastrop, Texas, in lieu of a bond in the amount of

$100,000.00, number AC-2018-0407A. Defendant is charged with Intoxication Manslaughter,

which is a second degree felony.

2. Defendant, confinement and restraint is illegal because bond is excessive,

oppressive and beyond the financial means of Defendant, in violation of the Eighth and Fourteenth

Amendments to the United States Constitution, and Article I   11, 13 and 19 of the Texas

Constitution, and Articles 1.09 and 17.15 of the Texas Code of Criminal Procedure. Defendant,

was arrested on April 7, 2018, and has not been indicted within 90 days.

3. Defendant respectfully requests this Court to order a personal recognizance bond

in order that Defendant, will have an opportunity to obtain release from incarceration pending

trial.

Application for Writ of Habeas Corpus - Page 1

 WHEREFORE, PREMISES CONSIDERED, Defendant, prays that the Court grant and

issue a Writ of Habeas Corpus to the Sheriff of Bastrop County of Bastrop County, Texas, directing

and commanding production of Defendant 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 Defendant should

not be discharged from such illegal confinement; or that Defendant, be allowed a personal

recognizance bond. Defendant further prays that the personal recognizance bond be conditioned

that Defendant appear at the hearing to await further orders of the Court.

Respectfully submitted,

ANDERSON & ANDERSON LAW FIRM, P.C.

710 Water Street
Bastrop, Texas 78602
Tel: (512) 581-9099
Fax: (512) 321-9009

By: /s/ Kathleen Anderson _____

Kathleen M. Anderson
State Bar No. 00789122
Attorney for Terry Nelson

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document was

served on the District Attorney's Office, Bastrop County, Texas, by electronic filing.

/s/ Kathleen Anderson

Kathleen M. Anderson

Application for Writ of Habeas Corpus - Page 2