Robinson, Olin Anthony ( 2015 )

PD-0974-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/15/2015 2:27:11 PM
December 16, 2015 Accepted 12/15/2015 4:00:23 PM
ABEL ACOSTA
No. PD-0974-15 CLERK
IN THE
COURT OF CRIMINAL APPEALS
OF
TEXAS
OLIN ANTHONY ROBINSON,
Petitioner,
vs.
THE STATE OF TEXAS,
Respondent.
Petition in Cause No. 05-05-7221 from the
24th Judicial District Court of Jackson County, Texas
and the Court of Appeals for the Thirteenth Supreme Judicial District
of Texas in Cause No. 13-13-00571-CR
PETITIONER'S STATEMENT REGARDING THE COURT
GRANTING THE STATE'S MOTION TO EXTEND TIME
TO FILE ITS BRIEF
TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS:
COMES NOW OLIN ANTHONY ROBINSON, Petitioner, and files his
Statement Regarding the Court Granting the State's Motion to Extend Time to File
its Brief, and in support of said statement would respectfully show the Court the
following:
1.
Robert E. Bell, Esquire, the Jackson County District Attorney, has always
been properly and timely served regarding the appellate litigation in the above-
entitled and numbered cause. The Court is requested to take judicial notice of
Petitioner's Exhibit "A" attached to this statement. Page 2 of the exhibit reflects
the e-mail address given by District Attorney Bell in which the Petition for
Discretionary Review was served. The document was received and opened by
District Attorney Bell. This Court did not receive a response from District Attorney
Bell concerning the Petition for Discretionary Review.
The Court is requested to take judicial notice of Petitioner's Exhibit "B"
attached to this statement. Page 2 of the exhibit reflects that Petitioner's Brief on
the Merits was served to the same e-mail address given by District Attorney Bell.
However, District Attorney Bell chose not to open the e-mail. The reason that the
State' s Brief on the Merits is late is not due to any fault of Petitioner's counsel but
is due to the neglect of District Attorney Bell in not opening his e-mail. Petitioner's
counsel is highly offended that that State's current counsel would intimate that the
State was not properly and timely served. Such statements by the State' s current
are totally untrue and stretch creduelty to its limits. This Court should seriously
reconsider its granting the State the additional time to file its Brief on the Merits
based upon the untrue statements of its present counsel.
Respectfully submitted,
WILLIE & ASSOCIATES, P.C.
By:/sl Joseph R. Willie, II, D.D.S., J.D.
Joseph R. Willie, II, D.D.S ., J.D.
4151 Southwest Freeway, Suite 490
Houston, Texas 77027
(713) 659-7330
(713) 599-1659 (FAX)
SBOT# 2 1633500
attyjrwii@wisamlawyers.com
ATTORNEY FOR PETITIONER
OLIN ANTHONY ROBINSON
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was
served via e-service to Robert E. Bell, Jackson County District Attorney, 115 W.
Main Street, Room 205 , Edna, Texas 77957, Jim Vollers, 2201 Westover Road,
Austin, Texas 78703 and the State Prosecuting Attorney, P.O. Box 12405, Capitol
Station, Austin, Texas 78711 , on the 15th day of December, 2015.
lsi Joseph R. Willie, II, D.D.S., J.D.
Joseph R. Willie, II, D.D.S ., J.D.
CERTIFICATE OF COMPLIANCE
I certify that Petitioner' s Statement submitted complies with TEX. R. APP. P.
9 and the word count of this document is 304. The word processing software used
to prepare the document and to calculate the word count is Windows 7.
lsi Joseph R. Willie, II, D.D.S ., J.D.
Joseph R. Willie, II, D.D.S., J.D.
Envelope Details Page I of2
Print this page
Case # PD-0974-1S
Case Information
Location Court Of Criminal Appeals
Date Filed 07/28/201505:49:16 PM
Case Number PD-0974-15
Case Description
Assigned to Judge
Attorney Joseph Willie, II
Firm Name Willie & Associates, P.C.
Filed By Joseph Willie, II
Filer Type Not Applicable
Fees
Convenience Fee $0.00
Total Court Case Fees $0.00
Total Court Filing Fees $0.00
Total Court Service Fees $0.00
Total Filing & Service Fees $0.00
Total Service Tax Fees $0.00
Total Provider Service Fees $0.00
Total Provider Tax Fees $0.00
Grand Total $0.00
Payment
EXHIBIT
Account Name Willie & Associates, P.C.
Transaction Amount
Transaction Response
$0.00 I - -- - -
Transaction ID 10269459
Order # 006263183 -0
-------.--- - - -- - --- --------- -----------------
Petition for Discretionary Review
Filing Type EFileAndServe
Filing Code Petition for Discretionary Review
Filing Description Petition for Discretionary Review
Reference Number 9999
Comments
Status Accepted
Accepted Date 07/29/2015 II :48:38 AM
Fees
Court Fee $0.00
...... / . ~ ,,..,,, . ,..
Envelope Detail s Page 2 of2
Service Fee $0.00
Documents
Lead Document Olin.Robinson.pet.review.2.final.pdf [Original] [Transmitted]
eService Details
Date/Time
Name/Email Firm Service Type Status Served
Opened
Lisa C. McMinn 07/2912015
EServe Sent Yes
information@spa.texas.gov 08:55 :44 AM
Jackson County
Robert E Bell 07/29/2015
District Attorney's EServe Sent Yes
eCmitchell@yahoo.com 12:06:21 PM
Office
Envelope Details Page 1 of2
Print this page
Case # PD-0974-1S
Case Information
Location Court Of Criminal Appeals
Date Filed 11105/201510:30:31 PM
Case Number PD-0974-15
Case Description
Assigned to Judge
Attorney Joseph Willie, II
Firm Name Willie & Associates, P .C.
Filed By Joseph Willie, II
Fi ler Type Not Applicable
Fees
Convenience Fee $0.00
Total Court Case Fees $0.00
Total Court Filing Fees $0.00
Total Court Service Fees $0.00
Total Filing & Service Fees $0.00
Total Service Tax Fees $0.00
Total Provider Service Fees $0.00
Total Provider Tax Fees $0.00 EXHIBIT
Grand Total $0.00
Payment I II ' ] "
Account Name Willie & Associates, P.e.
Transaction Amount $0.00
Transaction Response
Transaction ID 12585374
Order # 007712000-0
- - - . - - -..- - - - - -
Brief
Filing Type EFileAndServe
Filing Code Brief
Fi ling Description Brief of Petitioner on the Merits
Reference Number 9999
Comments
Status Accepted
Accepted Date 11109/201507:30 :39 AM
Fees
Court Fee $0.00
Envelope Detail s Page 2 of2
Service Fee $0.00
Documents
Lead Document Olin.Robinson.pdr.brief.merits. finaL l .pdf [Original] [Transmitted]
eService Details
Date/Time
Name/Email Firm Service Type Status Served
Opened
Jackson County
Robert E Bell
District Attorney's EServe Sent Yes Not Opened
ef_mitchell@yahoo.com
Office
Lisa C. McMinn 11106/2015
EServe Sent Yes
information@spa.texas. gov 10:54:29 AM