PD-0293-15
PD-0293-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 3/18/2015 3:22:53 PM
Accepted 3/19/2015 9:41:12 AM
CASE NO. ABEL ACOSTA
CLERK
In the Court of Criminal Appeals
Austin, Texas
KAREN LADELL ADAMS
Petitioner
March 19, 2015 V.
STATE OF TEXAS
Respondent
Appealed from the Second Court of Appeals
Fort Worth, Texas
Court of Appeals Cause No. 02-13-00184-CR
MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
NOW COMES, Karen Ladell Adams, petitioner, who makes and files
the following motion for extension of time in which to file her petition for
discretionary review, and in support thereof would respectfully show:
Page 1 of 4
I.
CERTIFICATE OF CONFERENCE
This is to certify that a conference was held with the state’s attorney
regarding the merits of this motion and the requested relief. Counsel for
the state advised that she did not oppose the requested relief.
II.
On February 5, 2015, the second court of appeals sitting in Fort
Worth, Texas handed down its opinion and judgment affirming petitioner’s
conviction and sentence in cause number 02-13-00184-CR, styled Karen
Ladell Adams v. State of Texas. In addition to this petition for
discretionary review, undersigned counsel also represents Karen Ladell
Adams’ son, Gordon Ray Lewis, and is in the process of preparing and filing
a petition for discretionary review in case number PD-0173-15, styled
Gordon Ray Lewis v. State of Texas.
III.
The petition for discretionary review in this matter was due March 9,
2015. Petitioner seeks an additional nine days in which to file her petition
for discretionary review.
Page 2 of 4
IV.
Good cause exists for this extension. As stated above, counsel for
petitioner also represents Gordon Ray Lewis in his appeal before this Court,
and the petition for discretionary review is due in that case on March 19,
2015. This case and Gordon Ray Lewis’ case are somewhat intertwined, in
that Karen Ladell Adams was convicted of retaliation by threat for
statements made after the indictment of her son for capital murder.
Counsel for Adams miscalculated the due date for the petition for
discretionary review in this matter. This miscalculation was inadvertant
and was not deliberate or the result of conscious indifference.
V.
No previous extension to file a petition for discretionary review has
been requested or granted. No further extensions will be necessary because
the petition for discretionary review is being filed contemporaneously with
this motion.
VI.
Petitioner Karen Ladell Adams is no longer incarcerated in the Texas
Department of Criminal Justice, institutional division, but is now on parole.
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WHEREFORE, PREMISES CONSIDERED, Karen Ladell Adams
prays that her motion for extension to file her petition for discretionary
review in the above styled and numbered cause be sustained, and that she
have up to and including March 18, 2015 in which to complete and file her
petition for discretionary review. Petitioner prays for such other and
further relief, both general and special, at law or equity, to which she may
show herself to be justly entitled.
Respectfully submitted,
By: /s/Michael W. Minton
MICHAEL W. MINTON
State Bar No. 14194550
THE LAW OFFICES OF
MICHAEL W. MINTON, P.L.L.C.
6100 Western Place, Suite W0541
Fort Worth, Texas 76107
mminton@mintonlaw.com
Telephone: 817-377-9200
Facsimile: 817-377-9201
CERTIFICATE OF SERVICE
I hereby certify that on March 18, 2015, a true and correct copy of the
above and foregoing document was sent U.S. certified mail, return receipt
requested and/or facsimile transmittal to all counsel of record in the above-
styled and numbered cause.
/s/Michael W. Minton
MICHAEL W. MINTON
Page 4 of 4
Adams, Karen Ladell
Combined Opinion