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FILED
Eloctronically
‘oRt9-0447
2019-04-18 05:00:16 PI
Jacqueline Bryant
Cope 8585 Traneacton #122768"
JOHN L. ARRASCADA, # 4517
GIANNA VERNESS, # 7084
KATHERYN HICKMAN, #11460
350 S, CENTER STREET, 5TH FLOOR:
RENO, NV 89520-8083
(775) 337-4800
Attorney for Petitioner
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA IN
AND FOR THE COUNTY OF WASHOE,
THE STATE OF NEVADA,
Plaintiff, CASE NO: CR19-0447
v.
DEPT. NO. 4
WILBER ERNESTO MARTINEZ GUZMAN,
Defendant.
!
PETITION FOR WRIT OF HABEAS CORPUS
TO: 'THE HONORABLE CONNIE STEINHEIMER, JUDGE OF THE SECOND
JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA, IN AND FOR THE
COUNTY OF WASHOE;
TO: SHERIFF OF WASHOE COUNTY, DARIN BALAAM; IIIS COUNSEL,
DISTRICT ATTORNEY CHRISTOPHER HICKS;
COMES NOW, the petitioner, Wilber Ernesto Martinez Guzman, by and
through his counsel, John L. Arrascada, Gianna Vernoss, and Katheryn Hickman,
and pursuant to NRS 34.360 to NRS 84.710, inclusive, states:
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That attorneys for petitioner are duly qualified and licensed and
permitted to practice in the Second Judicial District Court of the State of
Nevada;
‘That petitioner makes application for a writ of habeas corpus;
‘That petitioner is in custody and subject to restraint of his liberly
pursuant to Jacobson v, State, 89 Nev. 197, 200, 510 P.2d 866, 858
(4973);
‘That the evidence presented at the Grand Jimmy was insufficient to
establish probable cause to believe that Petitioner committed the
offenses with which Petitioner is charged;
‘That the petitioner waives the 60-day limitation for bringing him to trial,
That petitioner consents that if this petition is not decided within 15
days before the dato set for trial, the court may, without notice or
hearing, continue the trial to such date as it designates,
‘That petitioner has personally authorized the filing of thia petition.10
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8.
A previous petition for writ of habeas corpus has not been filed.
Respectfully submitted this K. day of PeeRe®, 2019
JOHN L. ARRASCADA
Washoe County Public Defonder
HN L.. ARRASCADA.
Washoe County Public Defender
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foputy Defender