WR-73,697-06,07,08,09
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/18/2015 10:58:45 PM
Accepted 8/19/2015 8:28:42 AM
WRIT
NO.
W06-‐00445-‐K(B),
W06-‐00448-‐K(B),
W06-‐00450-‐K(B)
and
ABEL ACOSTA
CLERK
W06-‐00453-‐K(B)
RECEIVED
COURT OF CRIMINAL APPEALS
WR-‐73,
697-‐06,
07,
08,
09
8/19/2015
ABEL ACOSTA, CLERK
In
the
Texas
Court
of
Criminal
Appeals
At
Austin
From
the
CDC
No.
4
Dallas
County,
Texas
EX
PARTE
RAUL
DAVID
JACKSON
11.07
Writ
MOTION
FOR
EXTENSION
OF
TIME
TO
FILE
FINDING
OF
FACTS
AND
CONCLUSIONS
OF
LAW
Bruce
C.
Kaye
2309
Boll
St.
Dallas,
TX
75204
(214)
722-‐7438
APPOINTED
WRIT
MASTER,
CDC
4
1
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
now
due
on
August
19,
2015,
per
this
Court’s
Order
dated
on
or
about
May
19,
2015.
II.
The
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
appointed
Writ
Master
has
been
involved
in
numerous
Appellate
and
trial
matters
in
both
state
and
federal
court.
Currently,
Counsel
is
long
medicare
fraud
case
involving
over
1200
pages
of
transcripts.
Counsel
is
also
completing
an
appointed
sentencing
memorandum
in
a
federal
case
involving
the
fraudulent
filing
of
30
million
dollars
of
tax
claims
with
the
IRS
(with
extensive
discovery
to
review).
Counsel
is
also
set
for
an
appointed
murder
trial
in
state
court
for
the
first
week
of
October
and
also
set
for
a
federal
trial
in
October
involving
4
terabytes
of
discovery
(medical
clinic
allegedly
prescribing
hydrocodone
for
everyone
who
asks).
2
IV.
An
additional
120
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
Facts
and
Conclusions
of
Law
for
the
Court.
WHEREFORE,
PREMISES
CONSIDERED,
the
appointed
Writ
Master
for
CDC
4,
Dallas
County,
Texas,
prays
this
Court
grant
his
Motion
for
Extension
of
Time
to
File
Finding
of
Facts
and
Conclusions
of
Law
and
set
a
new
due
date
for
120
days
from
the
current
due
date
of
August
19,
2015.
Respectfully
submitted,
/s/
Bruce
C.
Kaye
Bruce
C.
Kaye
TBN.
00784374
Appointed
Writ
Master,
CDC
4
2309
Boll
St.
Dallas,
Texas
75204
(214)
722-‐7438
office
(866)
649-‐8757
fax
bruce@brucekaye.com
3