Maples, Daniel Earl Jr. ( 2015 )

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» -_ .,7-.._; _ CELIA M sAMs ' "‘"RECENED!N ~
l :5;5' ``1``.:.-55 5;:`` ATTORNEY AT LAW COURT _01_= canquAL APPEALS
-.: » .-,e ' P Q BOX' 775 . 77 7 7
Rowlett TX 750'_30 0775 7 \\,UV 33 2015
Phone 214 587 7495 '-
~ j ~_; if ``Fax 1 866- 214 4350 5 Ab@ Acog€a mark
" "i¢l'»':NOvember17_, 2015 5' '
`` ~ԤHonorable Judges O5f 5The Court Of_ Criminal Appeals
'-;~577_:,'.``.7'?POB0X123118,Cap1talbtatlon 7 7 77
Austin, Texas 78711 _ _ 7 -_ '~
Attn 11. 07 writs
1»'_7. 17 Email celiamsams@gmail com
``11 ';Co'urt of Cr_iminal Appeals
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5 5 ' R Requestfor §xtenszon relating to §3c Parte Danzel Maples 5 5' \
Trlal Court NO ng 00670 WR'" 1513: ".jj.v 111 1 1 v l
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To the Honorab1e Juldges of the Court of Crimmal Appeals5
7 7 The purpose of this letter is to request additional time to complete the 7 7`` ;7
" § jinvestigation and prepare findings of fact and conclusions of7 1aw in this matter ‘ " '
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3 _ The Court master handling these wr1ts has been working diligently on this
'5 investigation however needs additional time for a number of reasons ‘
l. ``The writ application is extensive, including six grounds comprised of _
_ ’ ' twenty f-our pages, with a Memorandum of L5aw consisting of ov§_r one 15
;``; hundred pages and four hundred forty- -5f_ou``r pages of exhibits 7
7 , " ' lFurther Applicant has more recently f11ed additional' Motions and
5``57'“'.-_':Exh1bits His grounds include ineffective assistance of counsel
_ 7 ._ involuntary plea and Brady violations and perjured testimony, among
'_.5§', .:others `` ' ~ 7 » ~ 7.. ~
f 5 ' .7- '55'2. . Pursuant to a request by the trial court on August 6``,5 20l 5 this Court
1``1;;5'_ ;, .:granted an extension of time from the original deadline of August 37 2015
5`` ``_"_»to November 4 `` 5 ' ‘ »~ ‘~ ~ ~ ~ 4 ~ ~ ~ »
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v ``;f 3.'-1'Pursuant to it’ s own order this Coilrt on August 26 abated these 1 f_*
111'PrOCeed1ngS and set a new deadlme of November 24 " " ‘ ‘ l ' ' l
1 ii 4 On September 361, 2615 the Court Reporter made ava11ab1et6 the parties 1111 '- " 7
v 1:; , j -. § ja record 6f the plea and pumshment hearings whi6h occurred from Apr11 1
_~"1_,,‘25' A``pril 28§ 2006, consisting of 596 pages.`` She had re- generated it
h i_"f``r ."j1;1``r6m tapes,_ as her notes and exh1b1ts were no longer avallable _ §
_ '_ ``, ,_ § _ ii 1 " ,":_':5'1.,“October 30:" 2015 the Distrlct Attorney 111ed their Amended Response c
" 11 » "__;'j'~_‘.i"conslst1ng of57 pages ~_ § _: l _4 § _ *‘~. , /
d 1 '1 6 :On October 31,~14pp11cant filed his Response to State s Amended
.Fr-; 1".1" lResponse cons1st1ng 6135 pages ' . _
,. " .' » 2. |``Apphcant has slnce filed Apphcant s Proposed F1nd1ngs cons1st1ng of 14
._;__: llpage'S 4 ‘ c \ , . 1
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l 81_."'_"'T'he \7211_t Master has rev1ewed and analyzed all these documents but has
``1 .;_1 not had sufligient time to complete her Propose'd Flndmgs of F``act and _ x ``_
" " Con``clusions of L_aw and submit them to the trial court and allow time for .1 i'-;.~ w
~ - the trial court to_ review and approve them before the deadline set by this
Court m its order dated August 26, 2015 i. e. Tuesday November 24
Therefore 1 am requestmg thirty add1t1ona1 days to complete proposed
_, findmgs of fact and conclusions of- law,`` and- allow the trial court time to review and
j approve them for subm1ss1on to this Court jj ,i ' ,' ;;.1*' . ``- ,' l " §
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_ lf you have any questlons please contact me. _J» ;_`` §
:' ' ~ »“ 1 .'1. " 1 Vcry``.-t``ruly,yourS, ::}:.1, '~ f '»‘ ' ':``.
k YCellaM Sams “" f ;/1`` . ;
f ~ As Writ Master for ' `` '
1 _1 _ w 1 .. Judge Dom1n1que Colllnsi".'_:',"fj-§
" >11.1:1 1. 1 ;f:_: '._'~ ,~__..Cr1m1na1 D1strict Court #4" j__ l §