Sinclair, Thomas Henry

PD-0374-15
PD-0374-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 4/1/2015 10:51:45 AM
April 1, 2015 Accepted 4/1/2015 5:12:16 PM
NO. ___________________ ABEL ACOSTA
CLERK
THOMAS HENRY SINCLAIR § IN THE COURT OF CRIMINAL APPEALS
§
v. § STATE OF TEXAS
§
THE STATE OF TEXAS § AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES, the Appellant, THOMAS HENRY SINCLAIR, and moves for an extension
of time to file the Appellant’s Petition for Discretionary Review in this case, and in support thereof
would show the following:
I.
a. This case arises out of the 13th Judicial District Court of Navarro County, Texas
under Cause No. 33805-CR, styled State of Texas v. Thomas Henry Sinclair. It is
also pending in the Waco Court of Appeals under case number 10-11-00424-CR.
b. Appellant was convicted of Assault and sentenced to one year in prison and a
$4,000.00 fine. The judgment date was October 25, 2011. On March 5, 2015, the
Court of Appeals affirmed the conviction.
c. The deadline for filing the Appellant’s Petition for Discretionary Review is April 6,
2015.
d. Appellant requests an extension until May 6, 2015, to file the Petition for
Discretionary Review.
e. The reason for this request is that during the last few weeks counsel has been
working on the following:
1. Reply Brief in Ricardo Beltran v. State of Texas, No. PD-1076-14, in the
Court of Criminal Appeals in Austin.
Motion for Extension of Time to File Appellant’s Petition for Discretionary Review - Page 1
2. Brief in Robert William Cornwell v. State of Texas, No. PD-1501-14, in the
Court of Criminal Appeals in Austin.
3. Brief in Adolph Junior Menjivar v. State of Texas, No. 05-14-01028-CR, in
the Dallas Court of Appeals.
4. Brief in Lisa Ann Trevino a/k/a Lisa Ann Diaz v. State of Texas, No. 05-15-
00043-CV, in the Dallas Court of Appeals.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays that this Motion
be granted.
Respectfully submitted,
/s/ Brett Ordiway
BRETT ORDIWAY
Bar Card No. 24079086
SORRELS, UDASHEN & ANTON
2311 Cedar Springs Road
Suite 250
Dallas, Texas 75201
214-468-8100
214-468-8104 fax
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Motion for
Extension of Time to File Appellant’s Brief was mailed to Navarro County District Attorney’s
Office, 300 W. 3rd Avenue, Suite 203, Corsicana, Texas 75110, and to the State Prosecuting
Attorney, P. O. Box 12405, Austin, Texas 78711, on this the 1st day of April, 2015.
/s/ Brett Ordiway
BRETT ORDIWAY
Motion for Extension of Time to File Appellant’s Petition for Discretionary Review - Page 2