Simpson, Mark Twain ( 2015 )

PD-0599-15 PD-0599-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 5/18/2015 3:51:14 PM Accepted 5/19/2015 4:48:48 PM ABEL ACOSTA CLERK NO. ______________ IN THE TEXAS COURT OF CRIMINAL APPEALS _______________________________________________________________ MARK TWAIN SIMPSON Appellant v. THE STATE OF TEXAS Appellee ________________________________________________________________ FROM THE FIFTH COURT OF APPEALS CAUSE NO.05-14-00618-CR ON APPEAL FROM CRIMINAL DISTRICT COURT NO. 4 DALLAS COUNTY, TEXAS TRIAL COURT NO. F-1356596-K THE HONORABLE DOMINIQUE COLLINS PRESIDING APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW BRUCE ANTON State Bar No. 01274700 ba@sualaw.com May 19, 2015 SORRELS, UDASHEN & ANTON 2311 Cedar Springs, Suite 250 Dallas, Texas 75201 (214) 468-8100 (office) (214) 468-8104 (fax) 1 COMES NOW, MARK TWAIN SIMPSON, Appellant herein, and moves this court to issue an extension of time to file his petition for discretionary review, and in support thereof would show the court as follows: I. The opinion of the Fifth Court of Appeals in cause no. 05-14-00618-CR, affirming the conviction, was rendered on April 20, 2015. II. The number and style of the case in the District Court is No. F-1356596-K, State of Texas v. Mark Twain Simpson. III. Appellant was convicted of robbery 2nd and sentenced to twenty five years’ imprisonment. IV. The present deadline for filing the petition for discretionary review is May 20, 2015. V. No extensions of time to file the brief were previously requested. VI. The reason for this request is that during the last few weeks counsel has been working on the following: APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW - PAGE 2 1. Petition for Writ of Certiorari in Licho Escamilla v. William Stephens, in the Supreme Court of the United States. 2. Appellant’s Brief on Direct Appeal in Russell Donald Tindell, II v. State of Texas, case no. 10-15-00016-CR in the Tenth Court of Appeals of Texas. 3. Oral Argument in Cristal Paullett Richardson v. State of Texas, case no. 05-14-00523-CR in the Fifth Court of Appeals of Texas. 4. Jury Trial in Delvecchio Patrick v. State of Texas, case no. F- 1259295 in the 292nd Judicial District Court of Dallas County, Texas. WHEREFORE, PREMISES CONSIDERED, Appellant requests this court to grant an extension of time to file his brief until June 19, 2015. RESPECTFULLY SUBMITTED, /s/ BruceAnton BRUCE ANTON Texas State Bar No. 01274700 SORRELS, UDASHEN & ANTON 2311 Cedar Springs #250 Dallas, Texas 75201 (214) 468-8100 (214) 468-8104 (fax) ba@sualaw.com ATTORNEY FOR APPELLANT APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW - PAGE 3 CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the above entitled motion for extension of time was electronically served to the Appellate Division of the Dallas County District Attorney’s Office and to the State Prosecuting Attorney on this 18th day of May, 2015. /s/ Bruce Anton BRUCE ANTON APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW - PAGE 4