Jackson, Sharon Denise ( 2015 )

PD-0520-15 PD-0520-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 5/4/2015 11:05:06 AM Accepted 5/4/2015 3:53:42 PM CAUSE NO. ______________________ ABEL ACOSTA CLERK IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS ***** SHARON DENISE JACKSON, Petitioner / Appellant v. THE STATE OF TEXAS, Respondent / Appellee ***** On Petition from a Decision of the Court of Appeals for the Fifth District of Texas, Dallas Division in Cause No. 05-14-00283-CR MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TOM PAPPAS BURLESON PATE & GIBSON, L.L.P. 900 Jackson Street, Suite 330 May 4, 2015 Dallas, Texas 75202 Telephone: (214) 871-4900 Facsimile: (214) 871-7543 Email: tpappas@bp-g.com COUNSEL FOR PETITIONER/APPELLANT SHARON DENISE JACKSON 1 TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW, SHARON DENISE JACKSON, Petitioner herein, and Appellant before the Court of Appeals for the Fifth District of Texas at Dallas, Texas, and files her Motion to Extend Time to File Petition for Discretionary Review. I. On April 1, 2015, the Court of Appeals for the Fifth District of Texas, Dallas Division issued its Judgment and Opinion in Cause 05-14-00283-CR. The Petitioner/Appellant has not filed a motion for rehearing or en banc reconsideration with the Court of Appeals for the Fifth District of Texas, Dallas Division. II. The deadline for Petitioner/Appellant to file her Petition for Discretionary Review is May 1, 2015. Undersigned counsel has been in two (2) jury trials in the 30 days since April 1, 2015. Counsel needs additional time to work with the Petitioner/Appellant in preparing the Petition for Discretionary Review. III. Therefore, the Petitioner/Appellant respectfully requests that this Court pursuant to T.R.App.P. Rule 68.2(c) grant an extension of time to file the Petition for Discretionary Review to May 18, 2015, fifteen (15) days after the last day for filing the Petition. 2 PRAYER FOR RELIEF The Petitioner respectfully prays that this Court grant this Motion to Extend Time to File Petition for Discretionary Review to May 18, 2015. Respectfully submitted, BURLESON PATE & GIBSON, L.L.P. /s/ Tom Pappas _________________________________ TOM PAPPAS TEXAS BAR CARD NO.15455300 900 Jackson Street, Suite 330 Dallas, Texas 75202 Telephone: (214) 871-4900 Facsimile: (214) 871-7543 Email: tpappas@bp-g.com COUNSEL FOR PETITIONER/APPELLANT SHARON DENISE JACKSON CERTIFICATE OF SERVICE This will certify that a copy of the foregoing was delivered by placing same in the United States Mail via U.S. First Class mail to the following: Mr. G. Brian Garrison Ms. Lisa M. McMinn Dallas County District Attorney State Prosecuting Attorney 133 N. Riverfront Blvd., LB 19 P.O. Box 13046 Dallas, Texas 75207 Austin, Texas 78711 DATED the 1st day of May, 2015. /s/ Tom Pappas _________________________________ TOM PAPPAS 3