' ' .-.,'
No. _ _ _ _ __
IN THE STATE OF TEXAS COURT OF CRIMINAL APPEALS ON ORIGINAL ACTION JURISDICTION
APPLICANT'S PRO SE MOTION SEEKING COURT LEAVE TO FILE ORIGINAL ACTION APPLICATION FOR WRIT OF HABEAS CORPUS This document contains som€ pages that are of poor quality To the HONORABLE CLERK of said COURT: at the time of imaging.
Comes now IRSHAD ISMAIL BAIG, pro se Applicant in cause sub judice and
submits his pro-se MOTION SEEKING COURT LEAVE TO FILE ORIGINAL ACTION
APPLICATION FOR WRIT OF HABEAS CORPUS. RECEIVED IN COURT OF CRI~RINAL APPEALS I. SEP 14 2015 JURISDICTIONAL STATEMENT Abet Acosta, Clerk (1) Applicant IRSHAD ISMAIL BAIG is being restrained ofhis constitutional protected
liberty and property interest by virtue of Fort Bend County Cause Number 15-CCR-
180026 under color of STATE OF TEXAS statutory law contrary to and inconsistent
with the official Constitution(s) of Texas and United States of America. Texas Code
of Criminal Procedure (2012) Articles 11.01, 11.04, 11.05, 11.09.
II.
STATEMENT OF CASE
(2) Applicant was initially charged by Information under Article 22.01 (a) (1) Texas
Code of Criminal Procedure (See Attachment A- Fort Bend County Register of
Actions) on or about Aprill3, 2015.
Page 1 of 3
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(3) On or about May 13, 2015 Applicant filed his pro-se Application For Writ of Habeas
Corpus, Article 11.09 Tex. Code Crim. Proc. (2012). See Attachment A.
(4) In the United States Supreme Court Case ofLaChance V. Erickson 522 U.S. 262,
266; 118 S. ct. 753 (1998) and progeny it was plainly established "IF A LIBERTY
INTEREST IS CREATED BY STATUTE, DUE PROCESS REQUIRES NOTICE
AND MEANINGFUL OPPORTUNITY TO BE HEARD." Furthermore, in TARTER
V. HURY 646 F. 2d 1010 (5 1h Cir. 1981) and progeny this Circuit plainly established
"Pro se litigant entitled to have pro-se motions considered by court although he had
appointed counsel".
(5) Applicant IRSHAD ISMAIL BAIG, while proceeding pro-se during prosecution of
·Cause Number 15-CCR-180026, made numerous documented attempts to have the
Fort Bend County Court #3 entertain his pro-se Art. 11.09 Habeas Corpus
Application, however, said trial court has to date ignored every single pleading
Applicant had properly filed. During over 100 days of documented prosecution of
said Cause (supra) the trial court has set and reset said Cause for jury trial. Clearly,
taking the case to jury trial would blatantly moot and thus deny Applicant's State of
Texas and United States Constitutional Right/Entitlement to have his Art. 11.09
Application entertained, addressed by the trial court.
(6) On or about September 10,2015 Applicant filed his pro-se motion to "WITHDRAW
SUBJECT MATTER JURISDICTION IN ORDER TO PROCEED ORIGINAL
ACTION JURISDICTION OF TEXAS COURT OF CRIMINAL APPEALS." See
Attachment B [3 Motions].
Page 2 of 3 PREMISES CONSIDERED: (7) Applicant prays the Court to GRANT LEAVE TO FILE ORIGINAL ACTION
ARTICLE 11.09 Application For Writ OF HABEAS CORPUS attached hereto and
thereafter GRANT/ISSUE THE WRIT sua sponte; in all things. So Moved and
Prayed. ;'"_vy(.,.. \ '\ ' i
IRSHAD ISMAIL BAIG 11706 Nobility Drive, Stafford, TX 77477
Sworn to and Subscribed
before me hI J.J .M · /J1Etfl'ZA this/J..~y ofSeptember 2015
N!:::~ Fort Bend County, Texas
AMIN M MEERZA My Commission Expires · J June1.2016 ~
Page 3 of 3
( \
. . 9/11.'2015" ~ tyler paw .co.fort-bend.tx.us/CaseDetail.aspx?CaseiD= 1464206
REGISTER OF ACTIONS CASE No. 15-CCR-180026
State of Texas vs lrshad Ismail Baig § Case Type: Adult Misdemeanor- Filed by § Information § Date Filed: 04/13/2015 § Location: County Court at Law 3 §
RELATED CASE INFORMATION
Related Cases 14-CCR-177950 (Other)
pARTY INFOR:\IATION
Attorneys Defendant Baig,lrshad Ismail Male Asian Stafford, TX 77477 5' 8", 190 lbs
State State of Texas Richmond, TX 77469
Witness Baig, Kausar Jehan Female Asian Meadows Place, TX 77477
Witness Davis, Kelly Meadows Place, TX 77477
Witness Muratee, Shobana Female Asian SUGAR LAND, TX 77478
CHARGE INFORMATION
Charges: Baig,lrshad Ismail Statute Level Date 1. ASSAULT CAUSES BODILY INJURY FAMILY VIOLENCE 22.01 (a)(1) Class A Misdemeanor 11/09/2014
Evr.:ws & ORDERS OF THE CouRT
OTHER EVENTS AND HEARINGS 04/13/2015 Complaint 04/13/2015 Information 04/13/2015 Docket Sheet 04/13/2015 Case Filed (open event)- Criminal 04/13/2015 AJ;!plication/Reguest for Summons by State 04/13/2015 Warrant Information Sheet 04/20/2015 Summons - Mail lrshad Ismail Baig 04/20/2015 Summons Baig, lrshad Ismail Unserved 05/01/2015 Motion !No Feel Defendant Pro Se Motion for Self Representation at Jury Trial and All Related Court Process in Above Styled, Numbered Cause of Action 05/01/2015 Affidavit of Nolle Prosequi 05/13/2015 Writ of Habeas CorJ;!US Pre-Judgment 05/13/2015 Motion (No Feel to quash charging complaint; dismiss prosecution 05/22/2015 Reset 06/26/2015 Notice Certificate of Service 06/26/2015 Motion !No Feel Defendant Po Se Motion Requesting Court to Order its Clerk/Reporter to Make Complete Transcription 06/26/2015 Motion !No Feel for Court to set date on docket for Motions hearing 06/30/2015 Reset 06/30/2015 Reset 06/30/2015 Motion !No Feel Pro Se Motion to Hold All Proceedings in Abeyance 06/30/2015 Jury 07/14/2015 CoJ;!y Reguest 07/14/2015 Motion for Discoverv and order
http://tylerpaw .co.fort-bend.tx.us/CaseDetail.aspx?CaseiD= 1464206 1/2
. 9/11/2015 ___..: . \,..:"' tylerpaw.co.fort-bend.tx.us/CaseDetail.aspx?CaseiD=1464206
07/14/2015 Motion (No Fee} requesting finding offact w ith conclusions of law/ and order 07/14/2015 Motion (No Fee} objection to trial court consolidation of more than one charging instrument offense for prosecution in a single triaV and order 07/20/2015 Motion (No Fee) Def Pro-Se Motion Electin g Trial Jury to Assess Punishment . 07/20/2015 Motion (No Fee} 07/21/2015 Reset 07/21/2015 Motion (No Fee} To Dismiss Cause Sub Judice For Want of Prosecution (Pro Se) 07/28/2015 A!;!!;!lication for Sub1;1oena 08/18/2015 Subeoena- Constable 2 Kausar Jehan Baig 08/18/2015 Subeoena- Constable 2 Kausar Jehan Baig (Duce s Tecum) 08/18/2015 Subeoena - Constable 2 Kelly Davis 08/18/2015 Subeoena- Constable 4 Shobana Muratee 08/24/2015 Subpoena Baig, Kausar Jehan Unserved 08/24/2015 Subpoena Baig, Kausar Jehan Unserved 08/24/2015 Subpoena Davis, Kelly Unserved 08/24/2015 Subpoena Muratee, Shobana Returned Unserved 09/03/2015 Returned 09/03/2015 09/04/2015 Motion (No Fee} Applicant Pro Se Motion T o Expedite Disposition of Subject Matter In Article 11.09 Application For Haveas Corpus Relief 09/15/2015 Jury Trial (11 :00 AM)(Judi cial Officer Lowery, Susan G.) ProSe 0512212015 Reset by Co urt to 0613012015 06/3012015 Reset by Co urt to 07121/2015 0712112015 Reset by Co urt to 0911512015
http://tylerpaw .co.fort-bend.tx.us/CaseDetail.aspx?CaseiD= 1464206 2/2
,.-'
No. 15-CCR -180026 County Court at Law No. 3 Fort Bend County, Texas
) STATE OF TEXAS ) IN THE COUNTY COURT AT LAW ) NO.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) _______________________________) IN THE COURT OF CRIMINAL APPEALS OF TEXAS APPLICATION FOR WRIT OF HABEAS CORPUS (T.C.C.P. ARTICLE 11.09; 11.05; 11.04; 11.01)
Applicant: IRSHAD ISMAIL BAIG Date of Birth: April 07, 1964 STATEMENT OF CASE 1) On or about November 18, 2014, Kausar Baig, wife of Applicant herein,
made a criminal Complaint with Meadows Police Department of Fort Bend County, Texas implying family violence may have occurred. 2) A judicial Protection Order was applied for by C.P.S. (Child Protection Service) and was summarily granted, temporarily prohibiting Applicant from associating with or contacting his immediate family in Cause number 14-DCV-219, 272 on or about December 01, 2014. Earlier, on or about November 9th thru 14th, 2014, after C.P.S. officers had interviewed my wife, she was threatened in the
Page 1 of6
.. .· .. 15-CCR-180026 WRHCF Writ ol Habeas Corpus Pre-Judgment
No. 15-CCR -180026 .ii\l\11\ll\\l\11\Ill 14 BCR 968919 County Court at Law No.3 Fort Bend County, Texas
) STATE OF TEXAS ) IN THE COUNTY COURT AT LAW ) NO.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS )
IN THE COURT OF CRIMINAL APPEALS OF TEXAS APPLICATION FOR WRIT OF HABEAS CORPUS (T.C.C.P. ARTICLE 11.09; 11.04)
Applicant: IRSHAD ISMAIL BAIG Date of Birth: April. 1964 STATEMENT OF CASE 1) On or about November 18, 2014, Kausar Baig, wife of Applicant herein,
made a criminal Complaint with Meadows Police Department of Fort Bend
County, Texas implying family violence may have occurred.
2) A judicial Protection Order was applied for by C.P.S. (Child Protection
Service) and was summarily granted, temporarily prohibiting Applicant from
associating with or contacting his immediate family in Cause number 14-DCV-
219,272 on or about December 01,2014. Earlier, on or about November gth thru
14th, 2014, after C.P.S. officers had interviewed my wife, she was threatened in the
Page 1 of6 following manner "If you do not sign an Affidavit against your husband, today we will take official custody against your three children and put them in a State Home." 3) After the Protective Order was granted, the state of Texas as well as the County of Fort Bend, Texas elected to file and prosecute subsequent felony and misdemeanor charges against Applicant under Cause Numbers 14-DCR-68010 (felony) and under 14-CCR-177950, December 2014, January 2015. 4) On or about January 26,2015, the state ofTexas moved to Dismiss the protective Order and Court granted same. See: Attachment 1. 5) On or about April 13, 2015, the state of Texas moved to Dismiss felony prosecution in Cause Number 14-DCR-68010 to re~file same as Misdemeanor in Cause Number 15-CCR-180026, subjudice. 6) Applicant is now before the Court seeking habeas corpus relief from what he perceives to be unwarranted judicial harassment and blatant abuse of tax payer funds.
LEGAL CLAIM
7) Applicant is presently restrained of his liberty and property interests in Fort Bend County, Texas under color of State of Texas law in manner contrary to and inconsistent with the Constitution and law of the United States of America and specifically the FOURTH, FIFTH, SIXTH, and FOURTEENTH Amendments
Page 2 of6
' . thereto. 8) Applicant herein urges the writ of Habeas Corpus to issue forth against Fort Bend County Misdemeanor Complaint/Information number 15-CCR-180026 and Dismiss with Prejudice all charges incident thereto.
CAUSE
9) Applicant is a resident of Fort Bend County living at 11706 Nobility Drive, Stafford, Texas, 77477 thus in personam jurisdiction is satisfied. Jurisdictional authority is under T.C.C.P. Article 11.09 (2010); Article 11.04 (2013). 10) By virtue of criminal Complaint/Information in Cause number 15-CCR-180026 in Fort Bend County, Texas there has arisen applicable Bail Bond restraints as well as numerous and continuing open court appearances which mandate lost working days (Applicant recently laid off after 17 years because of taking too much time off for courts). All of paragraph 10 restraints conclusively establish injury to both Applicant's liberty interests and vested property rights which are severely injured. U.S. Supreme Court declares money as property and 19¢ injury states valid Claim. 11) Applicant complained of liberty restraint has been in effect since on or about December 15, 2014 some 130 days of restraint with continuing effect has elapsed, regardless of fact Applicant admonished the diverse judges, D.A., trial courts that Applicant desired a fast and speedy trial on merits. Applicant has not yet been to
Page 3 of6 trial and the State Prosecutors have NO valid evidence to set before a jury beyond that of mere speculation which cannot sustain a conviction. BARKER V. WINGO _ S. Ct._ (1972); WEBBER V. STATE, 29 S.W. 3d 226 (P.D.R. ref.) Tex. App. Hou. (14th) 2000; T.C.C.P. Art. 38.03 and progeny. 12) Finally, Applicant's constitutional rights are essentially a federal question and the instant Pleading is filed to exhaust state remedy at this point. 13) Applicant is supporting his legal claims herein with copy( s) of authentic evidence via sworn, notarized Affidavit( s) and relevant Fort Bend County documents. 14) Applicant has submitted herewith at Attachment A, B: State MOTION TO DISMISS PROSECUTION in Fort Bend County, 434th Judicial District, Cause Number 14-DCR-68010 and State INFORMATION in Cause Number 15-CCR-180026. 15) Applicant has submitted herewith as EXHIBITS 2, 3, 4 the sworn, notarized Affidavits of KAUSAR IRSHAD BAIG, at #2; ZAID IRSHAD BAIG , at #3; IRSHAD ISMAIL BAIG, at #4 16) At paragraphs 3, 4, 5 ofKAUSAR's Affidavit there exists material facts of fear that has coercion implications; irrebuttable declarations which is clearly negative of State criminal statutes required mens rea criteria. 17) At paragraphs 3, 4, 5 of ZAID's Affidavit there exists material facts,
Page 4 of6 negative of State criminal statutes required mens rea criteria. 18) At paragraphs 4, 5, 6 ofiRSHAD's Affidavit there exists material fact declaring negative impact upon State criminal statutes and specifically those relating to a person's actions or omissions under severe duress as established by sworn Affidavit ofKAUSAR IRSHAD BAIG, Exhibit 2 herewith. 19) A cursory review of all State evidence in this case even including its companion cases should reveal the State's entire prosecution of Applicant here has evolved from a woman under duress seeking only some kind of temporary protective order at suggestion of a neighbor/friend when neither ever realized the State (local) prosecutors could or would take more extreme action against her entire family. Regardless, however, the status quo of the present State position is frivolous at best. Please take note also of the Sworn Affidavits of Nolle Prosequi on file with Fort Bend County Court and Prosecutors attached herewith, at Attachments Aland A2. PREMISES CONSIDERED: 20) Applicant respectfully moves the honorable Court to DISMISS with/without Prejudice the State Information in Misdemeanor Cause number 15-CCR-180026.
So Moved and Prayed (\ ., )v7" IRSHAD ISMAIL BAIG
Page 5 of6
ORDER
On the _ day of , 20 15 came on to be heard the Application for WRIT OF HABEAS CORPUS under Texas Code Criminal Procedure, Article 11.09 (2014) and having given due consideration to same, including the evidence submitted therewith, the Court is of the opinion the WRIT be GRANTED/DENIED and on this same day the State Information is DISMISSED/ALLOWED to proceed.
Date: - - - - - - -, 2015 Presiding Judge
Page 6 of6
No. 15-CCR-180026 County Court at Law No.3 Fort Bend County, Texas
) STATE OF TEXAS ) IN THE COUNTY COURT AT LAW ) NO.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) )
CERTIFICATE OF AUTHENTICITY
I, IRSHAD ISMAIL BAIG, Habeas Corpus Applicant in above styled, numbered Cause of Action, hereby, herein swear upon oath under penalty of perjury according to law that all EXIDBITS and ATTACHMENTS evidentiary in scope, nature included with instant Certificate are true and correct photo copies of the Original documents on file with Fort Bend County and District Clerk Offices in Fort Bend County, Texas.
IRSHAD ISMAIL BAIG
Notary Public, in and for Fort Bend County, Texas
NO. 14-DCV-219,272
IN THE MATTER OF § IN THE 328th DISTRICT COURT
KAUSAR BA·IG APPLICANT § OF
AND
IRSHAD BAIG § FORT BEND COUNTY, TEXAS RESPONDENT
. AND ON BEHALF OF ZAID BAIG, AMAN BAIG, KABIR BAIG
MOTION TO DISMISS
COMES NOW, Tonika Davis, Assistant District Attorney of For~ Bend County, Texas, on behalf of Applicant and respectfully requests this Court to Dismiss Without Prejudice, the above entitled and numbered cause, which was instituted pursuant to Chapter 71. of the Texas Family Code.
Respectfully submitted,
Chad Bridges Fort Bend County Asst. District Attorney Attorney for Applicant SBN: 00790369 .
~D~ Tonika Davis Asst. Dist. Atty. Ft. Bend County
FILED Attorney for Applicant SBN: 24080003
JAN 26 2015 ..~~ 301 Jackson $treet AT 10- SS A.M. Richmond, TX 77469 (281) 341-4460 C:-rklfr~~C'!. TX
NO. 14-DCV-219,272
I~ THE MATTER OF § IN THE 328th DISTRICT COURT -
KAUSAR BAIG ...·. AP~LICilNT § OF ANI)
.. . IRSHAD BAIG § FORT BEND COUNTY, TEXAS '. ·.· ',RESPONDENT . .. . . -
AND ON BEHALF OF .·· .... ZA!D BAIG, .AMAN BAIG, KABIR BAIG
ORDER TO DISMISS -·. ~ on . this -~-day of
. ·~~~~- ,th~ ,tl!¢~ipn pf the Assistant Attorney to <iismiss( the .'- . :\~_'·::~~~e :~·~titled ~d numbered . . .... :: ;;;'. ·...:- :·: _._. :·:-..:·_::. :. ,. ' . . . ~ .. ·- •.-- ... _:_..·_:..· -~ cause for the foregoing reasons~' The "' .. ·
:: :~ouit : J1;ay~t}9: cpnsidered .· the .· pl~adings, and having }leard t:he ,'·,.,,i·,"• :_;·:A,' ~Vi~tmc;~ aJ1d ~nt of cotmael is satisfied that the above stat~ ...
reasons · are good and sufficient to authorize requested
... : ~ .. ·.. ··.
TliEREFQR£, it iS ()RDERED, AD.JUDGED AND DECREED that the ~~e . . .. ·- . _,_ f!,l1title.~ ~ _n~rred cause of action be and is hereby Dismissed
·. ·-::~:.:{:;~;~~op~·;: ~~~;u~C:e~ . ~·· · ·-~- sl:~ this ·~~day of . . •, < ~:~ ---~·.>:~:." -~~.··.· ~. · .":_ . . . - -<: . .·... :_. :: ·:· . . - .•·..-\-... .. -:_~.,_;:: :.·.'•.·:· .. ,,: . :- .::!'"': -..:- .
·'· ...
JAN 26 '1115 Jft'l.
AT· ·· >jO _- 'SS · k M. · . . Cflrl~~;~1X .·..
. _·, .. . :. . ·;·. .. . ;~ .· .
THE STATE OF TEXAS § § IN THE DISTRICf COURT OF § § FORT BEND COUNTY, TEXAS § I lf-.3 4- TR JUDJCW. DISTRICf Defaldant ..
MOTION TO DISMISS il . OD this tbc l 3 day of ·flpNIL , 20 16 • the Sbde ofTcus. by IIJd dlrougb the below·namcdAssistant DistrictAttomey, respectt\IUy nquesta the Court to DISMISS the above styled IDdllUIIIben:d crimiDa1 :;uin~chthedefeadantiscbqedwidltbeoffenseof ~ ~ Itt ~ ,fortbefollowing reasoa(s) to
The evidcDcc is iDsufticicut to prove tbis cue beyoad a RI8IOII8ble doubt; lbe cte&iadaat was coe'ricted iD aaodler cue: Cause Numba(s):_ _ _ _ _ _ _ __ Tbe complliDiDa witDas n:questl ctiaqUsgJ; • . Tbe cuc baa beeD Jefiled: Cause Number ~ fk..a 1 ULt FV The defendant is uuppreheDded; . The defendant is deceased; Tbc dd\:udant bu beeD paoted jrmi!Wiily D tbe clefcadant"l testimony; 1bc defeDdaDI made fbll ratitutioa. iaeludiq fees IIJd Court COlli; or Odaer, to wit:
Wherefore, it is prayed that the above cue be ctianjged with leave to rcfile,
RespectfiiOy submiUed,
~ L ·::: Allistaat District Attomey
ORDER
__.._ to Dismiss is GRANTED on tbis -~--- day of ........Motion thlli...e
THE STATE OF TEXAS Ricba Kllmar 22.01 (a) (1) 13990031
vs IRSBAD ISMAIL BAIG
D.O.B.: 1964 DA CONTROL NO: 14-011029
CHARGE: CAUSES BODILY INJURY FAMILY ARREST DATE: NA/SUMMONS VIOLENCE
CAUSE NO: OFFENSE DATE: November 09, 2014
~ COURT AT LAW N0\3 AGENCY/ AGENCY NO: DEPARTMENT/ 20145075477 MEADOWS PLACE POLICE
RELATED CASES: ASSAULT CAUSES BODILY INJURY CO-DEF: FAMILY VIOLENCE
IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:
Before me, the undersigned Assistant District Attorney of Fort Bend county, Texas, this day appeared the undersigned affiant, who under oath says he. has good reason to believe and does believe that in Fort Bend County, Texas, IRSBAD ISMAIL BAIG, hereafter styled the Defendant heretofore on or about November 09, 2014, did .then and there intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig by pushing him with Defendant's hand.
It is further presented that at the time of the offense alleged above Zaid Baig was a member of the defendant's family or household or in a dating
,- relationship with the defendant. c.n :Jao ""0 ::0 (,.) r- -u m == <a 0 en \D. AGAINST THE PEACE .AND DIGNITY OF THE STATE.
SWORN TO .AND SUBSCRIBED BEFORE ME
AFFIANT
MISDEMEANOR COMPLAINT AGENCY)
...
- • No. t4-DCR-868oto
~ ) STATE OF TEXAS ) ) v. ) BEFORE THE 434m DISTRICT \ ) COURT OF FORT BEND COUNTY. IRSHAD ISMAIL BAIG, ) . TEXAS ' ~ ) . Defendant, Pro Se -) . .. '· ) :. ."l
. )
.. SWORN AWIDAVIT .. · ,; ... . ;. ~~ I, KAUSAR IRSHAD BAIG, herebY, herein swear upon oath under penalty of perjury according }· ·' · ·.,·tO law that the following declarations, a~ ~of fact, paragraphs 1 thru 5 are true · · · .· &nd. correct being based upon my own personal knowledge and experience. ·1) 1 was bom August. 1972 and presently reSide at 11706 Nobility Drive in Stafford, Texas __ 77477 and my telephone number is 281-658-2640. On or about November 09, 2014 at above · .;o<iesidenCe my husband Irshad lsoiail Baig and I had a misunderstimdiilg; disagreement resrilting .. ·~-: in a·serious aigUJ;Deot concerning our financial position. ·
2) ·Although at the suggestion and ~istance of my friend_ I w8s taken to a nearby police station where I signed some form of Complaint ~gainst my husband, I~ too nervous to read the · ··· CcXnplaint so I merely signed at the place I was told to sign by policeman. 3) Days- on or about November 20, 2014, I was questioned by C.P.S.:-~ informed that my children could be taken away from me by the State of Texas if I refused to sign papers for some. . "Piotective Order." Hooked at the papers and signed them for fear oflosing my cbildrei:t. 1 ~ rea4 those~ either. ._,-_,
.4) My children are my life and if they were taken away from me, I could DOt live. I believe Mr. ,Enrico Fernando was one ofthe officers who talked to me. The State employees who 'talked with me were very nice but when it involved the S~ taking my cbil~ I heard and undeistOod very clearly and there was nobody that could quiet that tremendous fear in my heart.
S) I never suffei:ed any actual offensive, provocative or painful physical ilguries from my · husband lrsbad lsiDai1 Baig at any time during the names, dates, places incident as a basis for ·.. S1ate proseC'Qtion arising out of Fort Bend County, Texas.
... :: _:~
Further Affiant sayeth not.
Sworn To and Subscribed Before me on this J(gtft day of February, 2015 A.D.
Date: 02-\ \b \ ~0\ ~ · No '
~ AMIN M MEERZA .~My Commission Expires -:::::.:= June 1, 2016
, .. ·.. :·.·:·.;·.-
. ~.:.·~ '
"" No.l4-:QCR-068oto
STATE OF TEXAS . ) ) ) v. ) BEFORE TilE 434™ DISTRICT ) COURT OF FORT BEND COUNTY. IRSHAD ~ BAIG, ) ·, TEXAS • ~ ) Defendant, Pro Se ~) . .. ; ·" .:. ) )
. ·.· ·: SWORN AFFIDAVIT .'f_ .· : I,iAID IRSHAD BAIG, hereby, SW'ear upon oath under penalty of perjury according to law that .·.·.... the. following dec1ar8.tions, averments, ~- o( &ct, pamgraphs 1 tbru-6 are true and cOrrect · ,~based upon my own personal kno~e and experience. · . : . .
. . '1) I was bom ~ 1999 and ~yreside at 11706 Nobilizy Drive inS~ · ''T~ -n411 and my telephone numbens 281-658-2640. On or about November 09, 2014 at .. · .. : -~ teSidence my JJatmal p8reuts, Irsbad father and Kausar mother were ilrguing about · · .. . .. . · · :. :.iina:Dcial proble:ms. I was pm;ent with them. at the time and I reached over aod ~my · . · . · · ··-fiitber's mn in~ to voice my own~inion on the subjects they ·were~ MY father · ..: ..:,~ ii:l.a shocked or surprised manner. · . ..
.' :2)· My mother Kausar subsequently asked a friend to take her to the Police l>qJartment because $be \\185 still very angry at my. father. . Several days later I was interviewed by Child Protective Agency wo:dcers.
·· 3). I never did and still do not regard the argumentive language or actions ~fmy father :fi.sbad·or m.Y mothef Kausar either provocative or offensive· to or toward my personal being; throughOut · ·1he entire DlOIJth ofNovember 2014. . . .
4) I never witnessed any actual bodily ugmy of my mother Kausar or my own pen;on during 1he . : NovCIIlber 09,2014 argument~ my mo~ ~and filther lrsbad oVa: financial iSSues. . Jlfei1her was I involved in or aware of any o1her: such arguments during the year of2014~ · ·· . . · . ..·· 5) On or about. November 20, 2014 both my mother Kausar and m;yself (.Zaid) wen,qUestioiied :· . : ·.,by c.P.S. ()6icer ENRICO FERNANDO ~which time my statements were pUt on tape · :. · ..·~- Ai that time I specifically declared "I am not scaled or afraid of my fidher Irsbad". and ·
"I acted to intervene.. (idem sonan) (para. 1 supra.) with my father Irsbad at, during the time of argurilent the State's erroneous prosecution of my father is preSently based upon.
6) Based upon my own personal experience, in this subject matter under Cause No. 14-DCR- 068010, I can see no rational cause for my father lrshad to be put in jail or the tumultuous pain caused in my family during separation because of a "protective order" subsequently dismiSsed by · Judge Ronald R. . . I suffered no personal injury or offense at the hand of my father Irshad Baig at any time incident to State ofTexas Cause Number 14-DCR-068010.
Fmtb.er Affiant sayeth not.
ZAIDBAIG
· Sworn To and Subscribed · Before me on this /61ft day · of February, 2015.AD.
Date: ,,.oz..•""
No. 14-DCR-068010 .
) STATE OF TEXAS ) ) v. ) BEFQRE THE 434TH DISTRICT ) COURT OF FORT BEND COUNTY, IRSHAD ISMAIL BAIG, _) TEXAS ) Defendant, Pro Se ~ ":! -) ~ . ' ) )
SWORN AFFIDAVIT , I, IRSHAD ISMAIL BAIG, hereby, ~in swear upon oath under penalty of perjury according ' to law that the following declarations, averments, statements of fact, paragraphs 1 thru 6 are true and correct being based upon my own personal knowledge and experience.
1) I am the named Defen~ in Cause No. 14-DCR-068010 arising out ofFort Bend County, Texas. ·
2) I am proceeding pro-se in my own defense in said (para. 1 Cause Number,) being fully aware of the possible pitfiills, dangers of such representation, as well as being aware of my State of Texas and United States (federal) rights to defend myself personally.
3) · I have a sound, secure belief based upon reasoned study of applicable law that I have also · . filed numeroUs Other pro-se pleadings material and relevant to the disposition of all substantive due process of law issUes, questions arising out of the proceedings in Cause sub judice.
·. 4). • I have a sound, secure belief based upon a reasoned study of applicable case law authority, both state and federa4 that there is either no substantive evidence or only a scintilla of evidence eXisting that can objectively support the State of Texas felony charges I am on trial for in Cause sub judice.
5) I formally declare, aver and propose that any fwther prosecution of Fort Bend County Gause Number 14-DCR-068010 based upon presently non-existing evidence would be an abuse of ·Texas taxpayer funds. However, I do not have authority to remedy.
6) I further declare that at anytime incident to the substantive questions in Fort Bend County Cause Number 14-DCR-068010, I do not recall ever verbally or physically abusing or injuring any member of my family and specifically not my son ZAID nor my wife KAUSAR.
Further Affiant sayeth not.
IRSHAD ISMAIL BAIG
Date:
AMIN M MEERZA My Commission Expires June 1. 2016
· ...... .
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I ORIGINAL tfe~~:s/ yl'\' in the f('f\"'\~ records. ., No.15-CCR-180026 Copies NOcompared. County Court at Law No. 3 ~URA RIG:f, County ClarK Fort Bend County, Texas
) STATE OF TEXAS ) ) B~~~'IJGa c~~lr3 v. ) ) FO~~'{ () \ 1\\\~ IRSHAD ISMAIL BAIG, ) £('$Off\C~ ) "''t1 ~:no\\~ Defendant, Pro Se ) FORT B~ COUNfY, TEXAS ) )
AFFIDAVIT OF NOLLE PROSEQUI
I, ZAID IRHSAD BAIG, hereby and herein swear upon oath, under the penalty of perjury according to law that the following declarations, averments, statements of fact paragraphs 1 thru 5 are true, correct being based upon my personal knowledge and experience. ·
1) I was born December. 1999 in the United States and am a natural citizen thereof. I presently reside at 11706 Nobility Drive in Stafford. Texas 774 77 and my present telephone number is 281-658-2640.
2) I am the alleged Complainant in the above styled, numbered Cause of action due to erroneous state action(s) of Fort Bend County Officials. At no time whatsoever did I ever ask, request, seek or desire to file any type of legal action against my natural father Irshad Ismail Baig during the year 2014 and to date.
3) I was present, on the scene witness to all confrontation episodes over financial issues between my Mother Kausar Baig and Father Irshad Baig during November 2014 and at no time was there any actual, physical or emotional injury suffered by my own person as a result of Irshad Ismail Baig's actions or omission of action..
4) On or about November 20, 2014 both my mother Kausar and myself were questioned by State C.P.S. officer Enrico Fernando during which time my statements were tape recorded. At those times I specifically declared "I am not scared or afraid of my father Irshad."
5) Based upon my own personal experience in the subject matter under Cause No.180026 I cannot see any rational cause for my father Irshad to be prosecuted for something he simply did not do. Furthermore, it is repulsive to my mind to witness a State Agency twist facts around to make appearances that simply do not exist, such as the charged Information saying "did then and there intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig
,.
by pushing him with defendants hand." I hereby specifically declare nobody, including Irshad Ismail Baig, ever ca~ me any bodily injury as fraudulently expressed and charged by State officials in Cause No. 180026 supra.
Sworn to and Subscribed Before me on this 3~y of April 2015 ZAIDBAIG
Date: oolj_ 5o-;- 2015
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AMIN M MEERZA My Commission Expires June 1. 2016
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No. 14-CCR-177950 County Court at Law No. 3 Fort Bend County, Texas
) STATE OF TEXAS ) IN THE COUNTY COURT AT LAW . ) N0.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) )
AFFIDAVIT OF NOLLE PROSEQUI
I, KAUSAR IRSHAD BAIG, do solemnly swear, aver, declare upon oath, under penalty of peljury, according to law that the following two paragraphs are true and correct based upon my own personal knowledge and experience.
1) The only reason I ever signed any type paper work or document related to Fort Bend County, Texas Misdemeanor Cause Number 14-CCR-177950 was because I was placed in serious fear of losing parental custody over my children due to open threat by State of Texas employees interviewing and questioning me about a family incident.
2) I do not intend to prosecute, neither will I participate in any future court or State sponsored activity related to Fort Bend County, Texas Cause Number 14-CCR-177950.
Further Affiant sayeth not.
RECEIVED IRSHADBAIG APR 20 2015 11706 Nobility Drive Stafford, TX 774 77 DISTRICT ATTORNEY'S OFFICE , Phone: +1 281 6582640
COPY ·' ORIGINAL filed on J.;f - o. o - J s in the m r $ ct records. Copies NOT compared. LAURA RICHARD, County Clerk ·.. ~ . ·i (.) Bv ct?J ·
35615515
1 1 1 1 1 1 1 1 1 1~1 1 1 1 1 1 1 ~ ~I No. 15-CCR-180026 County Court at Law No. 3 Fort Bend County, Texas
) STATE OF TEXAS ) BEFORE THE COUNTY ) COURT AT LAW NO.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) )
AFFIDAVIT OF NOLLE PROSEQUI
I, ZAID IRHSAD BAIG, hereby and herein swear upon oath, under the penalty of perjury according to law that the following declarations, averments, statements of fact paragraphs 1 thru 5 are true, correct being based upon my personal knowledge and experience. ·
1) I was born December 24, 1999 in the United States and am a natural citizen thereof. I presently reside at 11706 Nobility Drive in Stafford, Texas 77477 and my present telephone number is 281-658-2640.
2) I am the alleged Complainant in the above styled, numbered Cause of action due to erroneous state action(s) of Fort Bend County Officials. At no time whatsoever did I ever ask, request, seek or desire to file any type of legal action against my natural father Irshad Ismail Baig during the year 2014 and to date.
3) I was present, on the scene witness to all confrontation episodes over financial issues between my Mother Kausar Baig and Father lrshad Baig during November 2014 and at no time was there any actual, physical or emotional injury suffered by my own person as a result of Irshad Ismail Baig 's actions or omission of action. .
4) On or about November 20, 2014 both my mother Kausar and myself were questioned by State C.P.S. officer Enrico Fernando during which time my statements were tape recorded. At those times I specifically declared "I am not scared or afraid of my father lrshad."
5) Based upon my own personal experience in the subject matter under Cause No.l80026 I cannot see any rational cause for my father Irshad to be prosecuted for something he simply did not do. Furthermore, it is repulsive to my mind to witness a State Agency twist facts around to make appearances that simply do not exist, such as the charged Information saying "did then and there intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig
by pushing him with defendants hand." I hereby specifically declare nobody, including Irshad Ismail Baig, ever caused me any bodily injury as fraudulently expressed and charged by State officials in Cause No. 180026 supra.
Sworn to and Subscribed Before me on this 3D~ay of April 2015 ZAID BAIG
~blic Fort Bend County, Texas Date: (}' LJ- j () ·-;- 2015
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15- CCR -180026 MOTI Motion (No Fee)
No. 15-CCR-180026 County Court at Law No.3 illlllllllllll\111 Fort Bend County, Texas
) STATE OF TEXAS ) BEFORE THE COUNTY ) COURT AT LAW NO. 3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) )
DEFENDANT PROSE MOTION TO HOLD ALL PROCEEDINGS IN ABEYANCE UNDER INSTANT CAUSE NUMBER 180026 PENDING DISPOSITION OF ARTICLE 11.09 T.C.C.P (2010) HABEAS CORPUS ACTION NOW BEFORE THE TEXAS COURT OF CRIMINAL APPEALS IN AUSTIN, TEXAS
TO THE HONORABLE JUDGE OF SAID COURT:
Comes now, IRSHAD ISMAIL BAIG, your Defendant pro se in Cause sub judice and
respectfully moves the Court to place all process in judicial abeyance on the instant Cause of
action pending final subject matter disposition by the Texas Court of Criminal Appeals. It is
well established law that two different courts of the same sovereign authority may not
entertain subject matter jurisdiction at the same time frame.
Case Facts
1) On or aboutAprill3, 2015, the 434th District Court ofFort Bend County, Texas
dismissed prosecution under Cause Number 068010 at State prosecutor request.-
However, on the same day, the same prosecutor re-filed the former charges relying on
same facts, subject matter in County Court at Law No. 03. Once ,a criminal case is
dismissed by proper judicial authority it is deemed by judiciary that the case never
existed. The new Cause Number became 15-CCR-180026. 2) On or about May 10,2015, Defendant filed his prose Application for Writ ofHabeas
Corpus, Article 11.09 (pre-trial habeas action) in the Texas Court of Criminal
Appeals. See: EXHIBIT "A" attached hereto, at paragraphs 11, 13 page 4 thereof, also
paragraph 16, page 4. PREMISES CONSIDERED: 3) Your Defendant prose respectfully submits to the Honorable Judge here that significant
substantive evidence and due process of law legal claims are timely, appropriately before
the Texas Court of Criminal Appeals that warrant complete dismissal of all fact related
criminal charges arising out of Fort Bend County against Defendant 4) Because the higher court has total habeas corpus pre-trial jurisdictio~ over subject matter
in Cause subjudice, the instant court is mandated to GRANT Defendant's instant pleading
and enter appropriate notice of ABEYANCE onto the Court's docket sheet, thereafter
directing the Court's Clerk to timely notify all interested party(s) hereto.
Respectfully Submitted;
(\~y -~ _ _ _ _ ,2015 IRSHAD ISMAIL BAIG
MOTION GRANTED/DENIED
PRESIDING JUDGE
No.lS-CCR-180026 County Court at Law No.3 Fort Bend County, Texas
) STATE OF TEXAS ) BEFORE THE COUNTY ) COURT AT LAW NO.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) )
CERTIFICATE OF SERVICE
I, Irshad Ismail Baig, hereby certify I have personally hand delivered true, accurate copy of foregoing PRO SE MOTION TO HOLD ALL PROCEEDINGS IN ABEYANCE to the District Attorney Office of Fort Bend County, Texas
\s:- A :?o Jljt-)~ '2015
Irshad Ismail Baig
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No. 15-CCR- 180026 - -l~DCR- 868810 · County Court at Law No. 3 Fort Bend County, Texas
) STATE OF TEXAS ) IN THE COUNlY COURT AT LAW ) N0.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS )
IN THE COURT OF CRIMINAL APPEALS OF TEXAS APPLICATION FOR WRIT OF HABEAS CORPUS (T.C.C.P. ARTICLE 11.09; 11.04)
Applicant: IRSHAD ISMAIL BAIG Date ofBirth: April 07, 19~ STATEMENT OF CASE 1) On or about November 18, 2014, Kausar Baig, wife of Applicant herein,
made a criminal Complaint with Meadows Police Department of Fort Bend
County, Texas implying family violence may have occurred.
2) A judicial Protection Order was applied for by C.P.S. (Child Protection
Service) and was summarily granted, temporarily prohibiting Applicant from
associating with or contactirig his immediate family in Cause number 14-DCV-
219, 272 on or about December 01, 2014. Earlier, on or about~~~VtEJ} . _ · MAY 13 2015 14th, 2014, after C.P.S. officers had interviewed my wife, she was threatened m the DISTRICT AnORNEY'S OFFICE Page 1 of6
.• ... e· . ..
following manner ''If you do not sign an Affidavit against your husband, today we
will take official custody against your three children and put them in a State
Home."
3) After the Protective Order was granted, the state of Texas as well as the
County of Fort Bend, Texas elected to file and prosecute subsequent felony and
misdemeanor charges against Applicant under Cause Numbers 14-0CR-6801 0
(felony) and under 14-CCR-177950, December 2014, January 2015.
4) On or about January 26, 2015, the state ofTexas moved to Dismiss the
protective Order and Court granted same. See: Attachment 1.
5) On or abotitApril13, 2015, the state ofTexas moved to Dismiss felony
prosecution in Cause Number 14-DCR-68010 tore-file same as Misdemeanor in
Cause Number 15-CCR-180026, subjudice.
6) Applicant is now before the Court seeking habeas corpus relief from what he
perceives to be unwarranted judicial harassment and blatant abuse of tax payer
funds.
LEGAL CLAIM
7) Applicant is presently restrained of his liberty and property interests in Fort
Bend County, Texas under color of State of Texas law in manner contrary to and
inconsistent with the Constitution and law of the United States of America and
specifically the FOUR1H, FIFTH, SIXTII, and FOURTEENTH Amendments
Page 2 of6
. ••.-. , ..••. ,, ·-····· •. ,•-_,.. ·'····· 1• . ~---· •<•;., --·~-.: •. :.--.~1<>~.-thereto. 8) Applicant herein urges the writ of Habeas Corpus to issue forth against Fort Bend County Misdemeanor Complaint/Information number 15-CCR-180026 and Dismiss with Prejudice all charges incident thereto.
CAUSE
9) Applicant is a resident of Fort Bend County living at 11706 Nobility Drive, Stafford, Texas, 77477 thus in personam jurisdiction is satisfied. Jurisdictional authority is under T.C.C.P. Article 11.09 (2010); Article 11.04 (2013). 10) By virtue of criminal Complaint/Information in Cause number 15-CCR-180026 in Fort Bend County, Texas there has arisen applicable Bail Bond restraints as well as numerous and continuing open court appearances which mandate lost working days (Applicant recently laid off after 17 years because of taking too much time off for courts). All of paragraph 10 restraints conclusively establish injury to both Applicant's liberty interests and vested property rights which are severely injured. U.S. Supreme Court declares money as property and 19¢ injury states valid Claim. 11) Applicant complained of liberty restraint has been in effect since on or about December 15,2014 some 130 days of restraint with continuing effect has elapsed, regardless of fact Applicant admonished the diverse judges, D.A., trial courts that Applicant desired a fast and speedy trial on merits. Applicant has not yet been to
Page 3 of6
'. trial and the State Prosecutors have NO valid evidence to set before a jury beyond · that of mere speculation which cannot sustain a conviction. BARKER V. WINGO _ S. Ct._ (1972); WEBBER V. STATE, 29 S.W. 3d 226 (P.D.R ref.) Tex. App. Hou. (14th) 2000; T.C.C.P. Art. 38.03 and progeny. 12) Finally, Applicanfs constitutional rights are essentially a federal question and the instant Pleading is filed to exhaust state remedy at this point. 13) Applicant is supporting his legal claims herein with copy(s) of authentic evidence via sworn, notarizedAffidavit(s) and relevant Fort Bend County documents. 14) Applicant has submitted herewith at Attachment A, B: State MOTION TO DISMISS PROSECUTION in Fort Bend County, 434th Judicial District, Cause Number 14-DCR-68010 and State INFORMATION in Cause Number 15-CCR-180026. 15) Applicant has submitted herewith as E~ITS 2, 3, 4 the sworn, notarized Affidavits of KAUSAR IRSHAD BAIG, at #2; ZAID IRSHAD BAIG , at #3; IRSHAD ISMAIL BAIG, at #4 16) At paragraphs 3, 4, 5 ofKAUSAR's Affidavit there exists material facts of fear that has coercion implications; irrebuttable declarations which is clearly negative of State criminal statutes required mens rea criteria. 17) At paragraphs 3, 4, 5 of ZAID's Affidavit there exists material facts,
Page 4 of6 negative of State criminal statutes required mens rea criteria 18) At paragraphs 4, 5, 6 ofiRSHAD's Affidavit there exists .material fact declaring negative impact upon State criminal statutes and specifically those relating to a person's actions or omissions under·severe duress as established by sworn Affidavit ofKAUSAR IRSHAD BAIG, Exhibit 2 herewith. 19) A cursory review of all State evidence in this case even including its companion cases should reveal the State's entire prosecution of Applicant here has evolved from a woman under duress seeking only some kind of temporary protective order at suggestion of a neighbor/friend when neither ever realized the State (local) prosecutors_ could or would take more extreme action against her entire family. Regardless, however, the status quo of the present State position is frivolous at best. Please take note also of the Sworn Affidavits of Nolle Prosequi on file with Fort Bend County Court and Prosecutors attached herewith, at Attachments Aland A2. PREMISES CONSIDERED: 20) Applicant respectfully moves the honorable Court to DISMISS with/without Prejudice the State Information in Misdemeanor Cause number 15-CCR-180026. So Moved and Prayed
IRSHAD ISMAIL BAIG
Page5of6
·e .!
ORDER
On the _day of , 2015 came on to be heard the Application for WRIT OF HABEAS CORPUS under Texas Code Crimina] Procedure, Article 11.09 (2014) and having given due consideration to same, including the evidence submitted therewith, the Court is of the opinion the WRIT be GRANTED/DENIED and on this same day the State Information is· DISMISSED/ALLOWED to proceed.
Date: _ _ _ _ _----7 2015 Presiding Judge
Page6of6
No.lS-CCR-180026 County ·court at Law No. 3 Fort Bend County, Texas
) STATE OF TEXAS ) IN THE COUNTY COURT AT LAW ) N0.3 v. ) ) ·FOR · IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) )
CERTIFICATE OF AUTHENTICITY
I, IRSHAD ISMAIL BAIG, Habeas Corpus Applicant in above styled, numbered Cause of Action, hereby, herein swear upon oath under penalty of perjury according to law that ·all EXHIBITS and ATTACHMENTS evidentiary in scope, nature iticluded with instant Certificate are true and correct photo copies of the Original documents on file with Fort Bend County and District Clerk Offices in Fort Bend County, Texas.
iRsHAD ISMAIL BAIG
11706 Nobility Drive, Staffoid, Texas 77477
.~fl'Y-~-'I:-: ·-- . ·-' Notary Public, in and for: AMIN M MEERZA My Commission Expires June 1, 2016
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NO. 14-DCV-219,272 : : ; ; i J:i· 1 : ,, : l ' ], I' I II 1 • ; I l ~ J
IN THE MATTER OF § IN THE 328th DISTRICT COURT
KAUSAR 81.IG APPLICANT § OF
AND
IRSHAD BAIG § FORT BEND COUNTY I TEXAS RBSPONDBNT . AND ON BEHALF OF ZAID BAIG I AMAN BAIG I KABIR BAIG
MOTION TO DISMISS
COMES NOW, Tonika Davis, Assistant District Attorney.of Port Bend County, Texas, on behalf of Applicant and respectfully requests this Court to Dismiss Without Prejudice, the above entitled and numbered cause, which was instituted pursuant to Chapter 71. of the Texas Family Code.
Respectfully submitted,
Chad Bridges Fort Bend County Asst. District Attorney Attorney for Applicant SBN: 00790369 .
~J:):i)L4u£) Tonika Davis Asst. Dist. Atty. Ft. Bend County FILED Attorney for Applicant SBN: 24080003
JAN 2&2015 .l~ 301 Jackson Street Ar~··ss A·u. Richmond, TX 77469 (281) 341-4460 ClltUIII.tt'l::C. TX
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NO. Ill--De.~- 68010 I IN 'I'JIE DII'I'BICT C01JRr OP I f I I I
MOTION TO DISMISS il . . . Olltbistbe t 3 day of IJ.pNP- .20 , 5 1 thDSIIIIeof'Teal.byadllaua(l11be
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-- vs 15-cCR.,-111111211 CCII l'.lllllplllal
IP"I-RS-==D-·n-=I-SMAI.........,==-L--BAI""""*'"""'G=--......... --o::o==o===-.....,.--.......:="-==--oa=:===_-~f D.O.B.: 64 DA ~NO: 14-011029
CHARGE: ASSAOLT CAOSES BODILY INJURY FAMILY ARREST !lAD: NA/SUMMONS
~: November 09 2014
AGBNC'Z/ AGBNCY NO: MEADOWS PLACE POLICE DEPARTMENT 20145075477
BELADD. CASES: ASSAULT CAUSES BODILY INJURY CC>-DBli': VXOLEN'CE
IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:
Before me, the undersigned Assistant District .. Attorney of Fort Bend County, Texas, this day appeared the Un.dersign.ed affiant, who under oath says he has good reason to ._believe and does believe that in Fort Bend County, Texas, msBAD X.SMJKU. BAXG, hereafter styled. the Defendant heretofore on or about N~ · 0.9, 2014, did then and there intentionally, knowingly, or recklessly cause bodily injury to Zaid Baig by pushing him with Defendant's hand.
It is further presented that at the time of the offense alleged above zaid Baig was a member of the defendant's family or household or in a (i(lting relationship with the defendant. = ·- en ~ _, -.., -r-· ;s w m . : .. (A)
(11 0 AGAINS!r TBE PEACE MID ·DJ:GRJ:TY OF. "fBB S'rAB. U)•
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. ) STATB OF TEXAS ) ) v. > BEFORE ~43418 DISnUcr ) cot1kr OF FORT BEND CO~ IRSHAD ~BAIG, ) TEXAS ·~ ) . Def-'ant, Pro Sc ~) •e ':. s i .-r, ) )
·.!Ill>_ ·~ ·;. S.WOBNAmDADI .~ ·.:· •. ·;.·!\· . ·I. icAusAR JRSHAD BAIG, haebj, ha:ein swe&rJUPCBl oath uadt:l' pe:uaJ:ty ofpeajury accou1iug }-- !. .· /1DJawthat6efbJJowiasdedazationss avwnecds, Sl(llteiiWdsof fad,pamgaBjokldJmS 81e1rue .. .·.. · 8iKi ~being based upon my own pemaud koowledge aod.apc:rience. · ... '1) lwas born August• tm aDd prC!ICidly :remde at 11706 Nobility Drive in~ Texas.';... T/477 aDd my 1f!1cphnne mmberis 281-658-2640. Oa.Ol' about'Nowmber 09, 2014 at &bow · . ;;'iesidmee my busbalwJJ:mhad.Jsmail ~ aod I had a mism..Jo•••...tmc; cfisa&recme:ut lf'881ting · . ·.-.., in &serious acaoum ccmcanina our finanr.JaJ position . ·
· :.. 2).. ·Aldlougb. at die sugesticm aDd ~·.-e ofmy fi.iead: I was 1Bkm to a Di:at,by poJlce Sbdion . whtft J. sigDed some fiJrm of Complaint 9inst my Jmsban:d, I~ too :oea:vous to read the · ~·· 0Rnp•iol so I maely siped at & pJace I was 1Dld 10 sip by policeman
. . l) Days Jater. on or about November~ 2014, I was qnestioned by c.P.S.::w.f irdic•ned tbat~ · c:h,iJdral c:ouJd be~ away from me by 1he S1Bte ofTexas ifl mtbsed to sip papcm mr ~- ..·:"PioCective Otdm:." I.Joobd at the papas aod sipecl than for fear oflosiDg my cbi1dn'liL. I . .w.- rea41hose pap(D either. . . ..r:i. . .
. ,/
.4) .My dlildleD a my 1ifC aod if1hey wae 1akal away from me, I could~ 1M. I believe Mr. ·.Emico Fernando was G:Je of'the officers who 1aibd to me. 1'he S181e c:mplo;ees who 1aJbd wi1h me.'WaeverJ Dice but'Wbal it~ the S.1BkiDgmy cbikkeD, I heml&Dd ~ . very c1eady aDd 1herc was nobody dJ8t could qoit:t 1hat tra•MW''*NJS fear in~ heart.
·..,._d S) I~ sufti::&d.aay actual offeasive. }imvocative or painfbl pJJ:,sical il:jmies fi:om my llshad Jslil8il Baig at any time dmiDg the~ dales. p1aces incideat as a basis 10r .· ·... Stale ~.arising out ofFort BeDel County, Texas.
1 ·. ·:· ..., •. . .··'.' . ' ..· ~ ·-· ,__ . -- ·" . - ." . • • ..., . • • • . . _, •. _... , ... - - 1 .. ___ . ·'·· ._, ., • •••• ;, --~ • -.-. /':",. -~--. '.. : ~- -· •.. :.·- .. <..,
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Further .Affi.aDt sayeth not.
Sworn To and Subscribed Before me on 1his ~day ·ofF~ 2015 A.D.
Date:·o~l \b \2-0\ ~ · ·.~':.
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) ) ) ) BEFOJm.THE 434m DISTRICT ) COUIUOFFORTBENDCo~ ) ·, TEXAS . . -~ ) ... ·.
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. . -:::I,·~ lRSHAD BAIG, haeby, ~upmOidh ubderpeaaltyofpajury ~tD~-1blit. · -.· · :·_-_::,tbQ-~dedanidons,avaowds,stataa!C?•'sc(&ct,paragraphs 111Jro.6am1rueml4conect : .· · ·..·. -~~ upalllDJOWDpal"lll ~&Ddexpa:ieace.. .... : . . . . .. .
.. ·, _'·:l) I_Wiis bam~·1999 aad~esL:atly ~~ 11706Nobiliiy Jlriveia~ .·. :.·~T--·77417 ~ aud my~ 1JP!Dber 281--658-2640. 0B: or ilboutNovemhcr09, 2014 ·- _..J.eSidenc:e my11Bf11Dtl I:rihad_&lb&!:t aad h. about · · ~ IS 'J'anpr~wae..... ·. · : .' _. · · ~·.: ....;~.1~ IwaspcDJtwidliban•1bc1imeaadli"JJf"hedoveraail~.a.f :- ·. ·. · . · . · · _--.~· ~-ja, •i•••q,t1o voice my own-opiuionon1be subjects ~Wale m....-.....Mf...... · :. · · · · - ......_... iba Wor piwlmamM& · . . . ,.· ..·;-'~.m.a '" . - . . - .... _. '.·:,·-· . , · . . :2l· )q JIMIIfher :g.,... SPbeeqlw*'ty aabd a friald 1D 1ab her to 1he Polk:e ~lmtiut-ieamae . • was.sliD very 8Df1'1 at my_falhl:r.·. Sewiral daJs later I was~ by Cbild Protective .. . ~ -A~woaba.. . .
. . : 3)) aever'ciidaad still do DOtn:pnl1he•llgUilwdive langpaae ~dons ~my ~:*·or_.·. · mj~·Kausar ei:lha-povccative oro&imive·1D ~1Qwad~pascmal beiD& ~ . _. . :_·~~~2014. . .. . .
4) . I~ wit•M md any actual bodily~ ofmyJIIOdla- TC~ or my cnmpeacm~dJe .. ·: ~-09,2014mawatent1M~mmy~K~aad~lrsbado¥rzfinauQati8ies. _Neiibriw&S . •. . . IimOived in or aw~i~e ofmy~ such. aqpaneiits cludDg the,_. of2014~ · · · .. . : . . . . .·._: ..:·:5): Oa'!'f.,_NOft.lllbez20,2014bothmyJDOti.rKansaraod~ ~~~ :: ·. : ·:··J;,y·c.P~~ENRICO FERNANDO ~which tii:Bmy slatHaods."wiDpit'oo.-.·_- -... · .. . .-~ .Ai 1hat1ime 1 speci&a1ly decJmed "1: am DOt scai'ed or 8fiaid ofmy~ Iailar.a.- · ' · . ·.. . ... ·. -~ ··~. . . .. . . . . •. . . . . .\ •. . . • ·<·. ..... . ....
. . . ~.
"1 acted to imerveoe" (idem sonan) (para. 1 supra.) with my father Irsbad ~during the time 'Of • argmDent tbe Stare's erroneous prosecution of my father is pteSeutiy based upm. . . . .
. 6) Based upon my own personal experi~ in this subject matter under Cause No. 14-pcR~ ()68010, I can see no rational cause for my father Irsbad to be put in jail or tbe tum~ pain · · , ·cause4 in my family during separation because of a "protccti~ Older" subsequcmly dismiSsed. by ·. Judge ~d R. . •· I suffeted DO personal injury or o1fense at 1he hand of my fidher · lrsbad Baig at any time~ to State ofTexas Cause Number 14-0CR-068010.
. .Further Affiant sayeth not. .. I .
ZAIDBAIG
· : ··.sWorn To aod Subscn"bed .·..Before me on thiS {&/Ia day · ofFetiruary, 2015.AJ>.
...
- • No.14-DCR..eA810
. ) · · STATE OF TEXAS ) ) ..v. ) BEFQRB mE 434'01 DISTRICT . . \ . ) ~OFFORI'BEND~ . .IRSHAD ISMAil;BAIQ .• . ,- -) TEXAS •) "· -) J.i )
..)
.... SWORNAD'JDAVIT ·. · J:'~~BAIG,Iaebyr~swe&rvponoaih ~paiahy ofpajury accordiDg .'[ .' w.tinlf.dad'6ie;1bllowDw clor;lealioas, an:piMjdS; slldo••ds offact, paragmpbs 1 thm 6 are true . . alalConect beiDg based upaD my own peaoaaJ kDow1edge aod axperieDce
· · 1).>'-{• tbe Daaecl ~in Causc,"No. 14--:pcR.-068010 arising out ofFoit ileud·Coum:y, . -~::-. . . .•. .
:
.2)·' ·1 ~.~po-se in my own defeDse in said (pa:a. 1 Cause Nnmbel;) being fbDy aw&Ee · .•-..po91P"bli1'Jiid8Ds. ..,.sofsaducpc&adaliDD, as wdl·as be:iog awmeofmy Stale of .. ~·aDd United s.a.s (fiedera)} rlibls 1D detead mySelfpasooally. .
. . . ·]):·I~ a SOUDd, secum Wbased ~ JJCamnrd SIDdy of appJirable Jaw1hat.J have also . :' filed....a.oiis Olhrrpm-sie pin rtmgs,...,. aDd ICievaad: to 1be ~ofan substatdive .· ~ ~-oflawissUes, qur:sdoDs arising out ofthe. proceedinp in Qmse ~judice.
· . ': :·4) ::; .I~ a..-ad. &ec;1lie Wbased upon aKBsonecl study of appJirable case law autholey, . ~ . . . . . . fedrnl,.1bat tbeae is ~DO subsfa..tiYe mdeace or only a sciublla of evideDce eciafinitbat ciill~ suppm;t1be SUB ofTexas felony chalgesl am on trial·for in Cause sUbjudice. .
S) · ·lfutmaJlY cJecl1n; avec aad popose that 8J1'f :&ulhet ~ ofFort Bead CoUDty Q1use ~ 14-IX!R:-068010 based upoa prwc::ad:y DOil-CZisdDg evideDce would be an abuse of ·T~·Iiuqayer fbads. BowCver; I do~ have jpcfla;u ity 1D tanedy.
· .. 6) •. I tbdher~~ ataai}time incidemtto 1htSubstacdjve ~in Fort Bend County .·Oiase Numhe:a-14-DCll-068010, I~ DOt recall~ 'Vabally or physicaJly abusing or i:ojurlDg .any fneiudi« ofmy family aod spedficaUy Dot my sanZAID nor my wife KAUSAR. : .
- •• • •••• .,.,_., .. - " · · · - • • • • • •·- ••---.~~-· ··.·-~---' ·-~--. • •• • •• <" ~---
·FUI1br:r AffiaDt sayeth ~. ·,.~y ,/ •;'.' IRSHAD ISMAIL BAIG
Date:
.- - - -.;... . -.r.:· .~- . . .
AlliN MMEERlA lly CommiSSion ExPir8S June 1; 2018
··. ' ..
.. , -~::
.. ·..
2 •'· ···~'·•·· •"•'-.~ ~ , ......... ·~ ••. ' .~ ···• . ••~.·••• ·~·:.•----· t· ··""···•···. ~- •••. ,.·, ·~,.-...·r.. :,· ~ .• ,.~ ;l,., :.
~-- a,. ·-. .. ~
·T.'. • .1""1'"k~a\J,. Ar\ ' coP:S ~ ORIGINAL filed on "" 'y\:; (
No. 15-CCR-180026 in the fr\)ta1. records. Copies NO · compared. County Court at Law No. 3 Fort Bend County, Teus ':RA RIL:f, County Clerk
STATE OF TEXAS
V.
IRSHAD ISMAIL BAIG,
Defendant, Pro Se
AllFJJ)AVIT OF NffiJ.E PROSEOm
I, UID IRBSAP BAIG. hereby and herein swear upon oath, under the penalty of perjury accordiilg to law that the following declarBtions, averments, stateDients of fact paragraphs l tbru 5 are 1n1e, conect being based upon my personal knowiedge and experience. ·
1) I was bomDece.mberiB 1999 in the United Statesandamaniltural citizen thereot: I ~Y ~de at 11706 Nobility Drive in Stafford, Texas 71477 and my present telephone number is 281-658-2640.
2) I ·am the alleged Complainant in the above styled, numbered Cause of action due to erroneous state action(s) of Fort Bend CoUDty Offici8Js. At no time whatsoever did I ever~ request, seek ·or deSire to file any type of legal action against my natural father Irshad Ismail Baig during the year 2014 and to date.
3) I was present, on the scenewi1Dess to all confrontation episodes over financial issues between my Mother Kausar Baig and ~ather Irsbad Baig during November2014 and at no time was there any actual, physi'* or emotional iDjmy suffered by my own person as a result oflrshad Ismail Baig's actions or omission of action. ·
4) On or about November 20, 2014 both my mother Kausar and myself were questioned by S1ate C.P.S. officer Enrico Fernando duriDg which time my stateinents were tape recorded. At those 1imes I specifically declared "I am not scared or afraid of my fatber Jrsbad." - 5) Based upon my own personal experience in the subject matter under C8use No.180026 I cannot see any rational cause for my father lrsbad to be .prosecuted for something he simply did not do. FurthermOre, it is repulsive to my mind to wimess a State Agency twist filets around to make appearances that simply do not exist, such as the charged Information saying · "did then and 1he.te intentionally, knowingly, or recklessly guse bodily inlm tO Zaid Baic
.·.,.•,..,,,t·· ···-·.•~... _ ...•. :-..;:1:"'·'-"... ·~·· -.·:'' ..... -...,,.,,, •• , , ··.·:~ •• :~··'""·:.····~; ...·, :, .. ·.·~.-.:. ·' , •••·-:··: .. ·.: •. ·.:.'.·.:....~ .. ... .
by pushing him with defendants hand." I hereby specifically declare nobody, including hsbad Ismail Baig. ever~ me any bodily injmy as fraudulently expressed·and charged by State · officials in Cause No. 180026 supra. ·
Sworn to and Subscn~ Before me on this l~y ~·~ . of Apri12015 · ZAIDBAIG
Date:
AMIN M.MEERZA My Commission Expires June 1; 2016
' '
No. 14-CCR-177950 Coaaty Court at Law No. 3 Fort Bead County, Taas ·
) STATE OF TEXAS ) IN 1HE COUNTY COURT AT LAW ) N0.3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) .Defendant. Pro Se ) FORT BEND COUNTY, TEXAS ) )
AF'J'IDAVIT OJi' NOLLE PROSEQUI
I, KAUSAR IRSHAD BAIG. do solemnly swear, aver, declare upon oath, under penalty of peajury, apcOrding to Jaw that the .following two par&&nlphs are true and correct based upon my own perscmal knowledge and experience.
1) Tbe only reason I ever signed any type paper work or documeDt related to Fort Bend County, Texas Misdemeanor Cause Number 14-CCR-177950 was because I was placed in serious fear of losing parental custody over my children due to open threat by State of Texas employees intervi~ and questioniDg me about a fiunily incident.
2) I do not intend to prosecUte, neither will I participate in any future comt or State sponsored activity related .to Fort Bend County, Texas Cause Number 14-CCR-177950.
Further Affiant sayeth not.
RECEIVED KA IRSHAD BAIG APR 20 2015 11706 Nobility Drive Stafford, TX 77477 DISTRJCT ATTDRNEY'S OFFICE Phone: +1 281 6582640 I • ·,I I . COPY . •' I 'I ORIGINAL filed on ~ - ao - J5 .:.- .;J·· in the ro (a a records•. ·Copies NOT compared'! . LAURA R~R~ COunty Clerk By. . . ~ - • •• . ... . ••. ~- ... ,-,'1.), • • •
n-... J... \\.1 ,_ '
15-CCR-180026 MOTI Motion (No Fee) 3680737
No. 15-CCR-180026 County Court at Law No. 3 Ill Ill Fort Bend County, Texas
) ) BEFORE THE COUNTY ) COURT AT LAW NO. 3 ) ) FOR ) ) ) FORT BEND COUNTY, TEXAS ) )
setting forth the Court reasons for not grant
Corpus relief prior to actual jury trial on subject
CAUSE:
1) On or about May 13,2015 Defendant filed his p
Corpus Art. 11.04, 11.09 Tex. Code Crim. Proc. (20 10)
2)
disposition before the Court instanter.
3) On or about June 30,2015, some 45 plus days beyond filing date ofsu ·
habeas corpus Application, the Court consolidated this Cause number with pre- Page 1 of2
...
existing cause number 14-CCR-177950 and summarily scheduled jury trial of both
21 5\2015. Cause number 14-CCR-177950 also has an unanswered Art.
habeas corpus filed on or aboutApril23, 2015.
p
leadings summarily continuing to jury trial then Defendant's
n I rights of meaningful access to courts; access to the Great
e injury, compelling Defendant to develop and file
PREMISES CONSIDERE
5) address and dispose of
. 1.04; 11.09) before July 21,
States requires. So Moved, Prayed.
SM~~IG, pro-se
: ~L-/ ,2015
MOTION GRANTED/DENIED: lt'~... -..-j
~ r
. Presiding Judge
Fort Bend County, Texas
Date: _ _ _ _ _ ,2015
Page 2 of2
No. 15- CCR-180026 County Court At Law No.3 Fort Bend County, Texas
) STATE OF TEXAS ) COUNTY COURT AT LAW . )
v. ) ) No.3 IRSHAD ISMAIL BAIG, ) ) Defendant, Pro Se ) FORT BEND COUNTY, TEXAS ) )
CERTIFICATE OF SERVICE
I, IRSHAD ISMAIL BAIG, hereby certify I have delivered a true, correct copy of foregoing, attached Motion:
(1) Defendant's ProSe Motion to Withdraw Subject Matter Habeas Corpus Jurisdiction
and Proceed Original Action in Texas Court of Criminal Appeals in Austin, Texas To:
a) Fort Bend County Clerk Office
b) Fort Bend County District Attorney Office
c) Fort Bend County Attorney Office
IRSHAD ISMAIL BAIG
No.lS-CCR-1180026 County Court at Law No. 3 Fort Bend County, Texas
) STATE OF TEXAS ) BEFORE THE COUNTY ) COURTATLAWNO. 3 v. ) ) FOR IRSHAD ISMAIL BAIG, ) ) Defendant, ProSe ) FORT BEND COUNTY, TEXAS ) )
DEFENDANT PROSE MOTION TO WITHDRAW SUBJECT MATTER HABEAS CORPUS JlJRISDICTION AND PROCEED ORIGINAL ACTION IN TEXAS COURT OFCRIMINALAPPEALS,AUSTIN, TEXAS
TO THE HONORABLE JUDGE OF SAID COURT:
Comes now IRSHAD ISMAil.., BAIG, pro-se Defendant in Cause sub judice and hereby, herein NOlliiES the Court of Defendant's intent to withdraw all subject matter Habeas Corpus jurisdiction in above styled, numbered cause of action; thereafter, to file said subject matter Habeas Corpus as Original action in Texas Court of Criminal Appeals sua sponte. CAUSE:
1) This habeas corpus action is a pre-trial action of which Defendant enjoys Texas and
Federal RlGHf/ENTI1LEMENT to have the Court(s) rule, decide, and address the
merits thereof.
2) The instant Court has been sitting 6n top of Defendant's pro-se pre-trial habeas corpus
pleadings over 115 days with<;mt addressing the facts set forth therein or transferring
Page 1 of2
said habeas corpus APPLICATION to the Texas Court of Criminal Appeals as
required by law. 3) The instant Court, to exacerbate the Defendant's Constitutional Right injury has also
scheduled this Cause of action for jury trial on at least two prior occasions and then
reset the Cause for trial on future dates. 4) It strongly appears to be a formidable abuse of discretion on the Court's behalf toward
Defendant, therefore Defendant withdraws said habeas pleadings in favor of
proceeding Original action jurisdiction in Texas Court of Criminal Appeals. It is so urged, moved, and decreed by Defendant this lOth day of September 2015.
IRSHAD ISMAIL BAIG
11706 Nobility Drive
Stafford, TX 77477
Sworn and Subscribed before me thi~D. day ofS~
KAVITA BHATT Notary Public for Notary Public STATE OF TEXAS Fort Bend County, Texas My eomm. Exp. _11-13-18
Pagel of2