WR-73,697-06,07,08,09
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/19/2015 2:50:52 PM
Accepted 5/22/2015 8:26:08 AM
ABEL ACOSTA
WRIT NOS. W06-00445-K(B), W06-00448-K(B), W06-00450-K(B) and CLERK
W06-00453-K(B)
RECEIVED
COURT OF CRIMINAL APPEALS
5/22/2015
In the ABEL ACOSTA, CLERK
Texas Court of Criminal Appeals
At Austin
From the CDC No. 4
Dallas County, Texas
EX PARTE
RAUL DAVID JACKSON,
Applicant,
11.07 Writ
MOTION FOR EXTENSION OF TIME TO TURN IN
FINDING OF FACTS AND CONLUSIONS OF LAW
Bruce Kaye
TBN. 00784374
2309 Boll St.
Dallas, TX 75204
(214) 722-7438
Appointed Writ Master, CDC 4
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
I.
On or about November 26, 2014, the undersigned was appointed as Writ Master by
the Honorable Judge Dominique Collins, Criminal District Court No. 4, Dallas County,
Texas. The Court’s Finding of Fact and Conclusions of Law are due on or about May 20,
2015.
II.
This issues to be resolved are as follows:
a. Is Applicant’s judgment and sentence void;
b. Does Applicant’s sentence violate double jeopardy;
c. Was Applicant’s plea involuntary; and
d. Did Applicant receive ineffective assistance of trial and appellate counsel.
III.
The undersigned Writ Master has been involved in numerous Appellate matters for
both state and federal cases. One case was a Capital Murder (non death penalty) which
produced a 100 page brief. Currently, there are three (3) appeals all due within the next 30
days and two (2) trials also scheduled in the same time frame. An additional 90 days is
required in order to properly read Applicant’s paperwork, review the State’s response,
research the issues and thereafter prepare the Finding of Fact and Conclusions of Law for
the Court.
WHEREFORE,
PREMISES
CONSIDERED,
the
undersigned
Writ
Master
prays
this
Court
grant
his
Motion
for
Extension
of
Time
to
Turn
in
Finding
of
Facts
and
Conclusions
of
Law.
Respectfully
submitted,
/s/ Bruce Kaye
BRUCE C. KAYE
By: Bruce Kaye
TBN 00784374
Appointed Writ Master
2309 Boll. St.
Dallas, TX 75204
(214) 722-7438
(866) 649-8757 facsimile
Bruce@brucekaye.com
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this document
was tendered to Dallas County District Clerk’s Office, on the 20th Day of
May, 2015, in accordance with the Texas Rules of Appellate Procedure.
/s/ Bruce Kaye
BRUCE C. KAYE
,