In the Southern District Court of Appeals

For the State of Missouri

State of Missouri, Plaintiff/Respondent )

Michael P. Hutchings, Attorney )

V ) Case No.#Cr495-388MC

) Appeal # 21211-1

Lee Allen Martin, Appellant/Defendant )

Pro Se )

Motion to Stay Execution of Sentence

Comes Now Defendant/Appellant, Lee Allen Martin, and requests of this honorable Court that the sentence imposed on August 19, 1996 be stayed.

Defendant/Appellant notes that on June 14, 1996 defendant/appellant was convicted of the charges of driving while revoked and possession of paraphernalia, both class A misdemeanors, and sentenced to two one-year sentences to run concurrently.

Defendant/appellant filed timely motion for new trial and was denied on 8-19-96 to which he filed notice of appeal to the Court of Appeals, Southern District and said Court affirmed said trial court decision on 2-9-98.

Defendant/appellant did file application for transfer to the Supreme Court of the State of Missouri and said application was accepted and is now before the Supreme Court of the State of Missouri.

It should be noted that defendant/appellant did produce $500.00 cash bond in this case and remained free on said bond. This bond has never been returned. The appellant has followed all instructions of the Courts of the State of Missouri; has appeared at every hearing, trial, and for oral argument before the Court of Appeals of the State of Missouri.

The defendant/appellant is also a candidate for Circuit Court Clerk for Howell County for the election year 1998.

The defendant/appellant has not shown a propensity to avoid the judgment of the Courts of the State of Missouri, only that said judgments are not in conformance with the statutes or the constitution of the State of Missouri or of the constitution of the United States of America.

Therefore, the defendant/appellant must request, pursuant to Rule 33.01 of the Missouri Supreme Court Rules, that he be freed on the established bond until the Supreme Court makes a decision.

Respectfully Submitted,


Lee Allen Martin

7050 County Road 2810

West Plains, Missouri 65775

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