Вы находитесь на странице: 1из 6
‘CAUSE No. NTO0926834 “STATE OF TEXAS § IW THE MUNICIPAL CouRT 8 vs. 8 (CITY OF Corpus CHRISTE 5 ‘GUY CONNOR WILLIAMS 5 NUECES COUNTY, TEXAS: AGREED MOTION TO DISMISS WITHOUT PREJUDICE Now comes the State, inthe above entitled and numbered causes and makes this ‘Agreed Motion to Dismiss without Prejudice fled on July 25, 2019, and for good cause ‘hows the following: ‘The State requests that the prosecution of the aboverenttld and numbered cause: be dismissed forthe following reason 1.Both parties would lke the Court to dismiss this case without prejudice, Wherefore, Premises Considered, the State prays that the Court dismiss all cases or ‘et thls motion for a hearing respect Bek eee ‘State Bar No. 24095861 Assistant Cty Attorney 120N. Chaparrel Corpus Christ, Texas 78401 (361) 886-2530 = Telephone (G81) 886-2567 — Telecopier Ema: EleS3@cctexas.com nao? sl CHRISTOPHER]. Ga.E Texas Bar No, 0079:765 Attorney at Lav TIN. Carancahua, Ste. 514 Corpus Christ, Texas 76401 (Got) 808-4446 ~ Telephone (G51) 232-4139 — Telecopier Email: evant 12008 Cortiicate of Service | certly that @ true and correct copy of the foregoing Agreed Motion to Dismiss. without Projuduce vias cent to the Defendant, through his counsel the 25th day of July, 2019 98 st forth below VIA FACSIMILE (361) 232-4139 and Emali CHRISTOPHER J. GALE ATTORNEY AT LAW. 7LLN. CARANCAHUA ST, SUITE 514 Gee T od. FRICF. SIMONTON CAUSE NO, NTOO92684 stATBOP TEXAS ' Ive Musicirat. coun “ ; crv or conus curastt Guy CONNOR WILLIAMS ; NUECES COUNTY. TEXAS NOW COMES Deion, Guy Comer Wiliams, an th Site of Teas ollie 1. Thisease is eure se for tia on July 25,2019. ‘On Monday, July22, 2019, the State of Texas fla Motion o Dismiss, asking the Couto approve 8 dismissal of al charges in th instant ease, Defendant didnot objet tsa mation ad joey aks this Court approve a damissl. As such, the pate atcpated a dismissal 3. On Tuesday, July 23, 2019, a hearing was held but the Cour didnot approve a dismissal or make ruling onthe State's motion, Instead the Court set “public hearing” on the State's Motion o Dismiss for Thursday, Sly 25,2019, a1 30am, 4. Also on Monday, July 22, 2019, counsel for Defendant began jury tial in the 148° Jui Distct Court, Nuoes County, Texas, in Cause No, 1TFC-2603E, State of Texas v. Charles Lope. Said teal was initially predicted to end no tater han the morning of Wednesday, ly 24, 2019 his mong). ‘That trial wok much fongr than anticipated, and as of the meldate ofthe filing ofthis motion that wal us not end and isnot preted to end unit sometime on Thursday, July 25, 2019, 5. Even if theta in the 148% District Cout were to end on July 24, 2019 (today), counsel far Defendant could not be ready for tral in istant case on July 25,2019, because counsel has no, and wil ‘not, have enough time to do the preparation necessary to begin al tet quickly afer being ina diferent lal week 6. The Sute of Texas and Defendant both anticipated a dismissal in his case —upon the State's ling (ofits Motion to Dismiss ~ in ie of a “public hearing.” Based on such, and fora multitude of easons, ther pry is prepared to proceed to tril on July 25, 2019, Asa result, and pursuant othe Texas Code ‘of Criminal Procedure, Section 29.02, both paris ae jin requesting the Court to continue this tia to later date agreed upon by 1. This contineaee is not sought fr delay only, bu oat justice may be done. WHEREFORE PREMISES CONSIDERED, the partis request that their Jin Motion for Continuance ‘be ranted and that this ase be continued to later date greed upon by all parties Respetly submited, By.Js! Christopher J. Gale Christopher J. Gale ‘Texas Bar No, 00793766 E-mail: Cris’@GaleLawGroup.com By. ds dmic dugenstin ‘Amie Augenstein “Texas Bat No: 24085184 smal: Amie@iGaleL.awGroup.com GALE LAW GROLF, FLUC ‘TUN, Carancahua St, Suite $14 Corps Christi, Texas 8401 Mailing Address: P.O. Box 2591 (Corps Christi, Texas 78403, Telephone: (361)808-4844 ‘Telecopier:(361)282-4139 City af Corpus Christ, Texas 120 N. Chaparal, Room 206, Corpus Christ, Texas 78401 Phone: (361) 886-2528 BrieS3@ectexas.com State Bar No, 24095861 CERTIFICATE OF SERVICE, Thereby ceri that on this the 24 day of July, 2019, a true and correct copy of the above and foregoing has been sen othe following counsel cf record by means indicated below: ‘Corpus Cuisti MuNiciPat. Cour 120 N Chaparral St Corpus Christ, Texas 78401 Fax: 361-826-2560 Fax: 361-826-2960 E-Mail: memail@cetexas.com Via Fax and E-Mail tsi Christopher J. Gale Christopher J. Gale CAUSE NO, NT00926834 STATE OF TEXAS VS. GUY CONNOR WILLIAMS IN THE MUNICIPAL COURT CITY OF CORPUS CHRISTI NUECES COUNTY, TEXAS ORDER GRANTING MOTION FOR CONTINUANCE ‘On the 2th day of July, 2019, the Court considered the Joint Motion filed by the State by and through her _attomey, Erie Simonton, andthe attorney forthe Defendant, Christopher Gale inthe above-entited and numbered cause; namely, Motion for Continuance ~ Jury Trial scheduled to commence on July 25,2019. ‘Mr. Gale ie presently representing a criminal defendant in an ongoing jury tial inthe [48 District Court, in eause # 17FC-2693-E, in Nueces County, Texas He is therefore unavailable Ina proposed Onder prepared by Mr. Ga, for this Court to sign, itstates that. subpoenas previously issued in this case shal continue in ful force and effec.” Tiss nt the law and witl no be 30 Ordered, Soe CCP 24.06(1) and Gentry. Stat, 770 S.W. 780, Ct. Crim. App. (1988) ITIS THEREFORE, ORDERED that the sting for the Jury Trial be continued. The atomeys re ORDERED to contact the Court hy Sps.on July 28,2019 with available dates foe rescheduling, [@ MOTION FOR CONTINUANCE OF JURY TRIAL SET ON JULY 25,2019 1s GRANTED. Signed this the 2th day of July, 2019. Fail doy ‘alae Judge, Manipal Court iy oF Comper Revd 4/30/2010 Mas dee