DOCUMENT 2
ELECTRONICALLY FILED
7/30/2019 11:11 AM
04-CV-2019-900219.00
CIRCUIT COURT OF
AUTAUGA COUNTY, ALABAMA
DEBRA HILL, CLERK

 DOCUMENT 2

That in Violation of the State Code and municipal ordinances, divests Charles Graddick
from acting as a Mobile Municipal Judge therefore the trial, conviction and sentenced of
the Defendant, Ronnie Lionel Parish is due to be over turned for lack of jurisdiction
following an evidentiary hearing.

That on April 22, 2019 within the 14 day window for offering notice of appeal, the
defendant filed a pro se request for appeal bond which has been ignored by the Municipal
Court; and the Defendant has been denied access to the courts.

That the City of Mobile, the City Council, Charles Graddick, and the Mayor of Mobile,
know that the directives of Charles Graddick to detain him under an unlawful conviction
are without jurisdiction and due to be set aside.

That Ronnie Lionel Parish was not committed or detained by virtue of any lawful

process, judgment, decree or execution issued by any court or lawfui Judge of the
Mobile Municipal Court, in this case where a lawful Judge had exclusive jurisdiction, nor
by virtue of a final judgment or decree of any competent Court of Criminal or Civil

jurisdiction, or of any execution issued upon such lawful judgment or decree.

That Ronnie Lionel Parish, your petitioner, seeks to be relieved from such detention and
imprisonment of the said confinement, and your petitioner now applies praying that a
Writ of Habeas Corpus, directed to the said Commissioner of Police, warden of Mobile
Metro Jail," Mobile Sheriff?s Office, City of Mobile, City Council, and Mobile Municipal
Court may issue on behalf of Ronnie Lionel Parish pursuant to the Statute in such case
made and provided so that he may be forthwith brought before this Honorable Court to
do, submit to and receive what the law may require.

That the Defendant, Ronnie Lionel Parish is being unlawfully detained under a wrongful

conviction by Charles Graddick, the Municipal Court and Mobile City Council and the

 

DOCUMENT 2

Mobile Mayor; and the Defendant having no other recourse for relief but to file Habeas
Corpus.

Wherefore, Premises Considered, the Defendant requests this Honorable Court issue a Writ
of Habeas Corpus and directed to the City of Mobile and Mobile Metro Jail. Comanding
the warden of Mobile Metro Jail, and warden Trey Oliver, to bring the body of the
defendant before this Honorable Court at a time and place to be appointed by the Court,
together with cause for the detention of said defendant.

ReSpect?illy submitted on this Eday of 2%2019.



Defendant, Ronnie Lionel Parish

State of Alabama 

Mobile County)

Before me, the undersigned authority in and for said county, in said state, personally
appeared, Ronnie Lionel Parish, who, being first duly sworn, deposes and says that he has. Read
the above and foregoing Petition for Writ of Habeas Corpus and that the facts contained therein
are true and correct.

Defendant, Ronnie Lionel Parish
Sworn To And Subscribed before me this 25 'lkd'ay ofi, 2019.

draw
Notary ?anew-z;

Christine C. Hernandez

 

DOCUMENT 2

Christine C. Hernandez (HEROS 1)

Attorney for the Defendant, Ronnie Lionel Parish
PO Box 66174

Mobile, AL 36660?1174



CERTIFICATE OF SERVICE

I hereby certify to the court that 1 have on this the 361.4- day of In; 2019 served a copy of the
foregoing via ?wif? 

Mobile City Attorney?s of?ce
20 6-91: ?aws.

?19st 3 99' /s/Christine c. Hernandez
Christine C. Hernandez