PD-0639-15 PD-0639-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/26/2015 4:14:30 PM
Accepted 5/28/2015 2:30:23 PM
No. 15- -PD ABEL ACOSTA
CLERK
(Court of Appeals No. 05-14-00243-CR)
IN THE
COURT OF CRIMINAL APPEALS
OF TEXAS
May 28, 2015
STEVEN LYNN JONES,
Petitioner,
v.
THE STATE OF TEXAS
MOTION TO EXTEND TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
On discretionary review from the Court of Appeals
Fifth District of Texas at Dallas
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
STEVEN LYNN JONES, Petitioner, pursuant to TEX.R.APP.P. 68.2(c),
respectfully moves the Court to extend the time for filing a petition for discretionary
review until 5 June 2015, and for cause represents as follows:
1. Deadline for filing Petition for Discretionary Review. A petition for
discretionary review is due to be filed on 29 May 2015.
2. Length of Extension Sought. The Petitioner seeks an seven-day extension
of time for filing a petition for discretionary review to and including 5 June 2015.
3. Basis of Request for Extension. The Petitioner has requested the
undersigned counsel to prepare and file a petition for discretionary review in this
case. The undersigned counsel has not been able to prepare and file a petition for
discretionary review in this case due to primarily to the time he has had to spend
caring for his wife since 4 April 2015, when she was diagnosed with sciatica. Since
then she has been essentially bedridden and has required virtually constant care.
The undersigned counsel has begun the preparation of a petition for
discretionary review but will not be able to complete it in time for filing on 28 May
2015. He will be able to complete a petition in time for filing on 5 June 2015.
4. Previous Extensions Granted. No previous extensions for filing a petition
for discretionary review have been requested or granted.
5. Identity of Court of Appeals. This case was appealed to and decided by
the Court of Appeals for the Fifth District at Dallas.
6. Case Number and Style in Court of Appeals. This case was styled Steven
Lynn Jones v. State of Texas in the Court of Appeals and bore No. 05-14-00243-CR.
6. Date of Judgment of Court of Appeals. The judgment of the Court of
Appeals was rendered on 13 March 2015 and timely-filed motion for rehearing was
denied on 29 April 2015.
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7. Identity of Trial Court. 401st Judicial District Court of Collin County,
Texas, Hon. Mark Rusch presiding.
8. Date of Trial Court’s Judgment. 11 February 2014.
9. Style and Case Number in Trial Court. State v. Steven Lynn Jones, No.
401-82891-2011.
Wherefore, the Petitioner prays that the time for filing a petition for
discretionary review in this case be extended to and including 5 June 2015.
Respectfully submitted,
/s/ Melvyn Carson Bruder
MELVYN CARSON BRUDER
TSB 03241000
6440 North Central Expressway
516 Turley Law Center
Dallas, Texas 75206
214.987.3500
214.987.3518 (FAX)
melvyn@melvynbruderlaw.com
Counsel for Petitioner
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CERTIFICATE OF SERVICE
This is to certify that on 26 May 2015 a true and correct copy of the foregoing
motion was served upon counsel of record for the State of Texas and upon the State
Prosecuting Attorney via first class United States mail, postage prepaid, in Dallas,
Texas.
/s/ Melvyn Carson Bruder
MELVYN CARSON BRUDER
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