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DOCUMENT  0069b


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TEODOSIO BAHADUE
Petition For Writ Of Habeas Corpus


[REF: Teodosio Bahadue vs E. W. Purdy  Habeas Corpus in the Circuit Court in and for Dade County, Florida.
            Case number HC-3237.]



IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT OF FLORIDA,
IN AND FOR DADE COUNTY

No. H.C.3237

PETITION FOR WRIT OF HABEAS CORPUS

TEODOSIO BAHADUE
Relator
vs.
E. WILSON PURDY
Sheriff of Dade County, Florida
Respondent

Relator, Teodosio Bahadue, through counsel files his petition for writ of Habeas Corpus and to set bond and says:

1.  That the relator is a resident of Dade County, Florida

2.  That the relator is confined and restrained of personal liberty in the Dade County Jail, 1321 N.W. 13 Street, Miami, Florida by your respondent, E. Wilson Purdy, Sheriff of Dade County, Florida.

3.  That your relator is being deprived of his personal liberty by virtue of being held without bond on a charge of First Degree Murder in violation of both State and Federal rights as guaranteed under the constitution of the United States and the Constitution of Florida since in this case the evidence is not strong nor the presumption great.

4.  That your relator was arrested and incarcerated on August 13, 1969 based upon a grand jury indictment being indictment No.2611 and charged with murder in First Degree.

5.  That the relator is charged with a murder which allegedly occurred on February 23, 1967 approximately two and one half years ago.

6.  That the evidence which lead to the relator indictment is based on hearsay and other inadmissable evidence.

WHEREFORE, your relator prays that this Honorable Court grant its most gracious writ of Habeas Corpus.

Dated: August 14th, 1969.

Herman Cohen

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