PD-1045&1048-15 RECEIVED IN TO: THE COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS SEP 22 2015 Cause No. 02-15-00157-CR, 02-15-00158-CR 1237940R, 1247941R ,ND Abel Acosla, Clerk THE STATE OF TEXAS IN THE 372™ DISTRICT COURT FILED IN TIFFNEY LYNNE MCADOO TARRANT COUNTY, TEXBSURT OF CRIMINAL APPEALS MOTION FOR EXTENSION OF TIME TO FILE ScP23 2C;a •A PETITION FOR A DISCRETONARY REVIEW TO THE HONORABLE COURT CRIMINAL APPEALS Abel Acosta, Clerk Pursuant to Tex, R. App. P. 10.1 and 38.6(d), the Appellee, Tiffney Lynne McAdoo files this unopposed Second Motion to Extend Time to file Appelle's Petition For A Discretionary Review. Appelle's opening Petition is due on September 18, 2015, Appelle request a 30 day extension of the time to file its Petition, making the Petition due on October 19, 2015. This the second request for extension of time to file Petition. Appellee relies on the following reasons, in addition to the requested extension: (1). Due to the ongoing of health difficulties with the attached medical report. Appellee seeks more time to file her Petition. (2). Appellee seeks the extension of time to be able to prepare a cogent and succinct petition to aid this Court in its analysis of the issues presented. The request is not sought to delay but so that justice may be done. All facted cited in this motion are with the personal knowledge of the Appellee signing this motion, therefore no verification is necessary under Rule of Appellee Procedure 10.2. PRAYER FOR RELIEF For the reasons set forth above, Appellee requests that this Courtgrant this Unopposed Second Motion to Extend Time to file Appelle's Petition and extend the Deadline for Filing the Appellee's Petition up to and including October 19, 2015. Appelle request all other relief to which may be entitled Respectfully, Tiffney Lynne McAdoo P. 0. Box 330274 Fort Worth, Texas 76163 CERTIFICATE OF SERVICE Icertify that onSeptember 16, 2015,1 mailed a copy ofthis motion to the following Court Of Appeals, Second District OfTexas. Tim Curry Criminal Justice Center. 401 w. Belknap, Suite 9000, FortWorth, Texas 76196-0211 IM7WIT/JESS THEREOF, we hai^eJjereupto set our hands this ) to day of September, 2015 Notary GREG UNDERWOOD My Commission Expires October 22, 2017 W"*^^*^^"^!^"" •W '*»'"«' Texas Health Huguley Hospital 111801 South Freeway, Burleson', TX 76028 (817)293-9110 Your Discharge Instructions Name: MCADOO, TIFFNEY DOB: 8/13/1975 12:00 AM MRN#: 6245123 Visit Date: 6/21/2015 12:40 PM Primary Care Provider: Name: Phone: Inpatient Care Providers: Attending Physician: DURAN MD, DONNA M. Texas Health Huguley Hospital would like to thank you for allowing us to assist you with your healthcare needs. Your physician has discharged you with the following plan: Discharge Instruction(s) Discharge to: Home Activity Instructions Discharge: Resume activities as tolerated Literature Provided: Medications, Other: Anemia info Diet: Regular Your Follow-up Instructions MCADOO, TIFFNEY has been given these follow-up instructions: With: Address: When: Follow up with primary care In 1 week provider 06/29/2015 Comments: Patient to follow-up with her physician. Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to '&> https://account.ahss.org/Account/Login" MRN 6245123 1 of 14 Jun/22/201512:07:20 Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to •':. https://account.ahss.org/Account/Login; MRN 6245123 2 of 14 Jun/22/2015 12:07:20 ft * 7,, s ' -* • .-• iviedication Instruction(s) Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to n https://account.ahss.org/Account/Login;? MRN 6245123 3 of 14 Jun/22/2015 12:07:20 Detailed Patient Education/Medication Material MCADOO, TIFFNEY has been given the following patient education materials: If you have any question(s), contact your physician Anemia, Iron L?e«ciencf i/usisssj Anemia is a condition where the size or number of red blood cells in the body is reduced. Iron is needed in the diet to make red cells. The red blood cells carry oxygen to all parts of the body. Anemia limits the delivery of oxygen to where it is needed. This causes a feeling of being tired and run down. When anemia becomes severe, the skin becomes pale and there is shortness of breath with exertion, headaches, dizziness, drowsiness and fatigue. The cause of your anemia is lack of iron in your body. This may occur due to blood loss (for example, heavy menstrual periods or bleeding from the stomach or intestines) or a poor diet (not eating enough iron-containing foods), inability to absorb iron from your diet, or pregnancy. If the blood count is low enough, an IRON SUPPLEMENT will be prescribed. It usually takes about 2-3 months of treatment with iron supplements to correct an anemia. Severe cases of anemia requires a blood transfusion to rapidly correct symptoms and deliver more oxygen to the cells. Home Care: 1) Increase the iron stores in your body by eating foods high in iron content. This is a natural way of building your blood cells back up again. Beef, liver, spinach and other dark green leafy vegetables, whole grain products, beans and nuts are all natural sources of iron. 2) If you are having symptoms of anemia listed above: ~ Do not overexert yourself. -- Talk to your doctor before flying on an airplane or traveling to high altitudes. Follow Up with your doctor in 2 months for a repeat red blood cell count, or as recommended by our staff, to be sure that the anemia has been corrected. Get Prompt Medical Attention if any of the following occur or worsen: - Shortness of breath or chest pain -- Dizziness or fainting -- Vomiting blood or passing red or black-colored stool © 2000-2013 Krames StayWell, 780 Township Line Road, Yardley, PA 19067. All rights reserved. This information is notintended as a substitute for professional medical care. Alwaysfollowyour healthcareprofessional's instructions. Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to ,. https://account.ahss.org/Account/Loginr; MRN 6245123 5 of 14 Jun/22/2015 12:07:20 i" 4 * jS (SOE dee urn FER ik GLU koe nate KOM plcx) '$$* " Ferrlecit, Nuleci't W What is the most important information I should know about sodium ferric gluconate complex? You should not usethis medication if you are allergic to sodium ferric gluconate complex or benzyl alcohol. Before using this medication, tell your doctor ifyou have iron overload syndrome, or ifyou receive regular blood transfusions. Tell your doctor about all other medicines you use, especially iron supplements you take by mouth. Also tell your doctor if you are pregnant or breast-feedinga baby. To be sure thismedication is helping yourcondition, your blood may need to be tested often. Visit your doctor regularly. What is sodium ferric gluconate complex? Sodium ferric gluconate is a type of iron. You normally get iron from the foods you eat. In yourbody, iron becomes a part ofyour hemoglobin (HEEM o glo bin) and myoglobin (MY o glo bin). Hemoglobin carries oxygen through your blood to tissues and organs. Myoglobin helps your muscle cells store oxygen. Sodium ferric gluconate complex is used to treat iron deficiency anemia (a lack of red blood cells caused by having too little iron in the body) in adults and children who areat least 6 years old. Sodium ferric gluconate complex is for people with kidney disease who are on dialysis. Sodium ferric gluconate complex may also be used for purposes not listed inthismedication guide. What should I discuss with my healthcare provider before taking sodium ferric gluconate complex? Youshould not use this medication if you are allergic to sodium ferric gluconate complex or benzyl alcohol. To make sure you can safely use sodium ferric gluconate complex, tell your doctor ifyou have any ofthese other conditions: • iron overload syndrome; or • if you receive regular blood transfusions. FDA pregnancy category B. Sodium ferric gluconate complex is not expected to harm an unborn baby. Tell your doctor if you are pregnant or plan to become pregnant during treatment. It is not known whether sodium ferric gluconate complex passes into breast milk or if it could harm a nursing baby. Do not use this medication without telling your doctor if you are breast-feeding a baby. Sodium ferric gluconate complex should notbe given to a child younger than 6 years old. How should I take sodium ferric gluconate complex? Sodium ferric gluconate complex is injected into a vein through an IV during your dialysis session. This medication must be given slowly, and the IV infusion can take at least 1 hourto complete. You may be shown how to use an IV athome. Do not self-inject this medicine ifyou do not fully understand how to give the injection and properly dispose ofused needles, IV tubing, and other items used to inject the medicine. Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to https://account.ahss.org/Account/Logiri MRN 6245123 6 of 14 Jun/22/2015 12:07:20 sodium ferric gluconate complex must be mixed with a liquid (diluent) in an IV bag before using it. If you are usingthe y' injections at home, be sure you understand how to properly mix and store the medicine. Do not mix sodium ferric ' v*-'' gluconate complex with any other medication or solution in your IV. y Each single-use vial (bottle) of this medicine is for one use only. Throw away after one use, even if there is still some medicine left in it after injecting your dose. To be sure this medication is helpingyour condition, your blood may need to be tested often. Visit your doctor regularly. Store at room temperature away from moisture and heat. Do not freeze. What happens if I miss a dose? Call your doctor for instructions if you miss a dose of sodium ferric gluconate complex. What happens if I overdose? Seek emergency medical attention or call the Poison Help line at 1-800-222-1222. Overdose symptoms may include severe weakness, loss of balance or coordination, rapid breathing, tremor, or seizure (convulsions). What should I avoid while taking sodium ferric gluconate complex? Avoid getting up toofast from a sitting or lying position, or you may feel dizzy. Get upslowly and steady yourself to prevent a fall. What are the possible side effects of sodium ferric gluconate complex? Get emergency medical help ifyou have any ofthese signs of an allergic reaction: hives, sweating, vomiting; severe lower back pain; wheezing, difficult breathing; swelling of your face, lips, tongue, or throat. Call your doctor at once if you have a serious side effect such as: • feeling like you might pass out; • chest pain, trouble breathing; • flushing (warmth, redness, or tingly feeling); • fast or uneven heart rate; or • dangerously high blood pressure (severe headache, blurred vision, buzzing in your ears, anxiety, confusion, uneven heartbeats, seizure). Less serious side effects may include: • pain, leg cramps; • dizziness, general ill feeling; • mild headache; • nausea, vomiting, diarrhea; or • pain, redness, swelling, or irritation around the IV needle. This isnota complete list of side effects and others may occur. Call your doctor for medical advice about side effects. You may report side effects to FDA at 1-800-FDA-1088. What other drugs will affect sodium ferric gluconate complex? Tell your doctor about all other medicines you use, especially iron supplements you take by mouth. There may be other drugs that can interact with sodium ferric gluconate complex. Tell your doctor about all medications you use. This includes prescription, over-the-counter, vitamin, and herbal products. Do not start a new medication without telling your doctor. Where can I get more information? Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to \$ https://account.ahss.org/Account/Login MRN 6245123 7 of 14 Jun/22/2015 12:07:20 ' •*-0' '" ' i'oui pharmacist can provide more information about sodium ferric gluconate complex. Remember, keep this and all other medicines out of the reach of children, never share your medicines with others, and use this medication only for the indication prescribed. Everyeffort has been madeto ensurethat the information provided by Cerner Multum, Inc. ('Multum') is accurate, up-to-date, and complete, but no guarantee is made to thateffect. Drug information contained herein may be time sensitive. Multum information has been compiled for use by healthcare practitioners and consumers in the United States and therefore Multum does not warrant that uses outside of the United States are appropriate, unless specifically indicated otherwise. Multum's druginformation does notendorse drugs, diagnose patients or recommend therapy. Multum's drug information is an informational resource designed to assist licensed healthcare practitioners in caring for their patients and/or to serve consumers viewing this service as a supplement to, and not a substitute for, the expertise, skill, knowledge andjudgment of healthcare practitioners. The absence of a warning for a given drugor drugcombination in no way should be construed to indicate that the drug or drug combination is safe, effective or appropriate for any given patient. Multum does not assume any responsibility for any aspectof healthcare administered with the aid of information Multum provides. The information contained herein is not intended to cover all possible uses, directions, precautions, warnings, drug interactions, allergic reactions, or adverse effects. If you have questions about thedrugs you are taking, check with your doctor, nurse or pharmacist. Copyright 1996-2012 Center Multum, Inc. Version: 1.01. Revision Date: 08/15/2012. Name MCADOO, TIFFNEY . If you would like electronic access to your i[ discharge instructions go to f Please bring the following to your follow up physician. Name MCADOO, TIFFNEY Ifyou would like electronic access to your discharge instructions go to / https://account.ahss.org/Account/Login 9 of 14 Jun/22/2015 12:07:20 MRN 6245123 „ *H •5 - Texas Health Huguley Hospital Clinical Discharge Summary PERSON INFORMATION Language English DOB 8/13/1975 12:00 AM Name MCADOO, TIFFNEY Age 39 Years PCP Race Black or African Sex Female Marital StatusSingle American Ethnicity Non-Hispanic or Med Service General Medicine MRN 6245123 Phone (817) 404-8376 Visit Reason Weakness or fatigue; Arrival 6/21/2015 12:40PM LOS 000 20:34 Acct# 8651535 symptomatic anemia, dysfunctional uterine bleeding fibroid uterus Patient Address: 4117 GERMAN POINTER WAY FORT WORTH TX 761233553 PROVIDER INFORMATION Admitting Physician: QASSAM MD, MEHBOOB S. Attending Physician: DURAN MD, DONNA M. Consulting Physician: None Referring Physician: None VITALS INFORMATION Last Recorded Measurement Result Last Recorded Vital Sign Result Date/Time: 06/21/2015 16:52 Temp 978 DegF Date/Time: 06/22/2015 10:29 Height (cm) 170.2 cm Date/Time: 06/21/2015 16:52 02 Sat 100% Date/Time: 06/22/2015 10:31 Weight (kg) 83.5 kg Date/Time: 06/21/2015 16:52 Respiratory 18br/min Date/Time: 06/22/2015 10:30 Body massindex 28.82 Rate Blood 123 mmHg / 49 mmHg Date/Time: 06/22/2015 10:31 Pressure Cognitive Status: Oriented x3Date: 06/22/2015 Name MCADOO, TIFFNEY If you would like electronic access to.your discharge instructionsgo to |; https://account.ahss.org/Account/Login 10 of 14 Jun/22/2015 12:07:20 MRN 6245123 L?Wv> v'8 y. 4l- '/-ijnctional Status: Resume activities as tolerated Date: 06/22/2015 MEDICAL INFORMATION Allergies Benadryl Smoking Status: Never smoked Immunizations No Immunizations Documented This Visit MEDICATIONS No Known Home Medications LABORATORY & DIAGNOSTIC RESULTS Laboratory or Other Results This Visit (last charted value for your 06/21/2015 visit) Hematology 06/22/15 04:26:00 Hct: 24.7 % - Normal range between ( 37.0 and 47.0 ) Hgb: 7.3 g/dL - Normal range between ( 12.0 and 16.0 ) MCH: 22.0 pg -- Normal range between ( 27.0 and 34.0 ) MCHC: 29.6 g/dL - Normal range between ( 32.0 and 36.0 ) MCV: 74.4 fL - Normal range between ( 82.0 and 101.0 ) MPV: 8.7 fL - Normal range between ( 9.4 and 12.4 ) Platelet: 358 x10'3/microL -- Normal range between (130 and 400 ) RBC: 3.32 x10'6/microL -- Normal range between ( 4.00 and 5.60 ) RDW: 20.5 % -- Normal range between (11.5 and 14.5 ) WBC: 4.60 x10'3/microL - Normal range between (4.50 and 11.00 ) RDW SD: 54.9 fL - Normal range between ( 36.4 and 46.3 ) 06/21/15 13:12:00 Basophils %: 0.2 % - Normal range between ( 0.0 and 2.0 ) Eosinophils %: 1.3 % -- Normal range between ( 0.0 and 5.0 ) Hypochrom: Moderate Lymphocytes %: 41.6 %-- Normal range between (15.0 and 41.0 ) Monocytes %: 6.1 % - Normal range between ( 0.0 and 12.0 ) Neutrophils %: 50.6 % - Normal range between (40.0 and 70.0 ) Polychromasia: Slight Schistocyte: Rare Target Cell: Rare Tear Cell: Rare Baso Stippling: Rare Name MCADOO, TIFFNEY Ifyouwould like electronic access to your discharge instructions go to ''£ https://account.ahss.org/Account/Login MRN 6245123 11 of14 Jun/22/201512:07:20 Anisocytosis: Slight Elliptocyte: Rare Slide Review?: Yes Neutrophils Abs: 2.4 x10'3/microL~ Normal range between ( 1.8 and 7.7 ) Lymphocytes Abs: 2.0 x10'3/microL -- Normal range between ( 0.6 and 4.5 ) Monocytes Abs: 0.3 x10'3/microL -- Normal range between (0.0 and 1.3 ) Eosinophils Abs: 0.1 x10'3/microL -- Normal range between ( 0.0 and 0.6 ) Basophils Abs: 0.0 x10'3/microL -- Normal range between ( 0.0 and 0.4 ) PLT Est: Normal Microcyte: Moderate Immature Granulocytes %: 0.20 %•» Normal range between ( 0.00 and 0.50 ) Immature Grans Abs: 0.01 x10'3/microL - Normal range between ( 0.00 and 0.05 ) Chemistry 06/21/15 13:12:00 AGAP: 11 mmol/L Albumin Level: 4.2 g/dL - Normal range between ( 3.5 and 5.2 ) Alk Phos: 42 Inter. Units/L-- Normal range between ( 35 and 105 ) ALT(SGPT): 11 Inter. Units/L - Normal range between ( 0 and 33 ) AST: 21 Inter. Units/L - Normal range between ( 0 and 32 ) Bili Total: 0.3 mg/dL -- Normal range between ( 0.0 and 1.2 ) BUN: 5 mg/dL - Normal range between ( 6 and 23 ) Calcium: 8.8 mg/dL -- Normal range between ( 8.4 and 10.2 ) Chloride: 103 mmol/L - Normal range between ( 98 and 107 ) C02: 23 mmol/L - Normal range between ( 22 and 29 ) Creatinine: 0.6 mg/dL - Normal range between ( 0.6 and 1.2 ) Potassium: 4.0 mmol/L - Normal range between ( 3.5 and 5.0 ) Sodium: 137 mmol/L -- Normal range between (136 and 145 ) Total Protein: 8.2 g/dL - Normal range between ( 6.6 and 8.7 ) Albumin/Globulin Ratio: 1.0 % -- Normal range between (1.0 and 1.8 ) GFR (MDRD): >110.0 mL/min/1.73 m.2 Glucose: 92 mg/dL - Normal range between ( 70 and 100 ) Bun/Creat: 8 Globulin: 4.0 g/dL -- Normal range between ( 2.0 and 4.0 ) Est CrCL (CG): 122.5 mL/min Immuno/Seroloqy 06/21/15 13:12:00 U Preg Test: Negative Urine 06/21/15 13:12:00 UA Appear: Clear UA Bacteria: 55 /hpf- Normal range between ( 0 and 88 ) UA Bili: Negative UA Blood: Negative UA Color: Yellow Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to https://account.ahss.org/Account/Logih 12 of 14 Jun/22/2015 12:07:20 MRN 6245123 _r'"' UA Glucose: Negative mg/dL UA Hyaline Casts: 0 /Lpf - Normal range between ( 0 and 3 ) UA Ketones: Negative mg/dL UA Leuk Est: Negative UA Nitrite: Negative UA pH: 6.5 - Normal range between ( 5.0 and 9.0 ) UA Protein: Trace mg/dL UA RBC: 3 /hpf - Normal range between ( 0 and 6 ) UA Spec Grav: 1.020 -- Normal range between (1.000 and 1.040 ) UA Urobilinogen: .2 EU perdL UA WBC: 2 /hpf -- Normal range between ( 0 and 2 ) UA Epithelial: 3 /hpf - Normal range between ( 0 and 4 ) Culture?: No UA Spec Type: Clean Catch Blood Bank 06/21/15 19:52:55 TRANSFUSED: TRANSFUSED 06/21/15 15:20:00 ABORh Recheck Interp: A POS 06/21/15 14:21:00 BBPRODUCT: Crossmatch ABORh: A POS Antibody Screen: Negative XM Interp: Compatible Ultrasound 06/21/15 15:09:27 US Pelvis Complete/Transvaginal Non-OB: US Pelvis Complete/Transvaginal Non-OB ORDERS INFORMATION Care plan field(s), including goals and instructions Problems No Problems Documented Procedures No Procedures Documented Encounter Diagnoses Anemia due to blood loss, chronic Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to V https://account.ahss.org/Account/Login MRN 6245123 13 of 14 "., Jun/22/201512:07:20 5i t { discharge Instruction(s) i * Discharge to: Home Activity Instructions Discharge: Resume activities as tolerated Literature Provided: Medications, Other: Anemia info Diet: Regular DISCHARGE EDUCATION INFORMATION Discharge Instructions: ANEMIA, Iron Deficiency (Adult) C Medication Leaflets: iron gluconate Follow up Instructions: With: Address: When: Follow up with primary care In 1 week provider. 06/29/2015 Comments: Patient to follow-up with her physician. Name MCADOO, TIFFNEY If you would like electronic access to your discharge instructions go to i| https://account.ahss.org/Account/Login MRN 6245123 14 of 14 Jun/22/201512:07:20 . el\is Complete/Transvaginal Non-OB MCADOO, TIFFNEY - 6245123 inal Report * Result Type: US Pelvis Complete/Transvaginal Non-OB Date: June 21, 2015 15:09 Result Status: Auth (Verified) Result Title: US Pelvis Complete/Transvaginal Non-OB Performed By: OLTERSDORF MD, TIMOTHY P. on June 21, 2015 15:25 Verified By: OLTERSDORF MD, TIMOTHY P. on June 21, 2015 15:25 Encounter info: 8651535, HMMC, Observation, 06/21/2015 - Final Report * Reason For Exam DUB. REPORT Endovaginal and transabdominal transducers were utilized to evaluate the pelvis. There is a2 1xi7xl.8cm diameter right ovarian cyst. The right ovary appears otherwise ultrasonically normal. The left ovary appears ultrasonically normal. The uterus is enlarged measuring 16.1 x 10.9 x 11.3 cm in diameter. There is a large uterine fibroid in the fundus of the uterus measuring 7.5 x 10.1 x 8.9 cm in diameter. This obscures the superior endometrial canal which is of normal width but contains a small amount of fluid. There are two nabothian cysts. There is no ultrasonic evidence of free pelvic fluid. Impression: Large fundal uterine fibroid. Small right ovarian cyst. Small amount of fluid in the endometrial canal. Dictating Dr. Oltersdorf, Timothy Dictated 06/21/2015 Signing Dr. Oltersdorf, Timothy Location HUGDPAXDS1 Signature Line ******* *Final********* Dictated by: OLTERSDORF MD, TIMOTHY P. Signed by: OLTERSDORF MD, TIMOTHY P. 06/21/15 15:25 Transcriptionist: TPO 06/21/15 15:25 RADRPT This document has an image crr-\ Completed Action List: * Order by QASSAM MD, MEHBOOB S. on June 21, 2015 14:18 * Perform by LE RDMS, NIKI NGA on June 21, 2015 15:09 1.%/<#.? Printed by: DURAN MD, DONNA M. />/p{ ? (sl^Z/iZ: Page lof 2 (Continued) Printed on: 06/22/2015 12:30 .-cl\ is Complete/Transvaginal Non-OB MCADOO, TIFFNEY - 6245123 inal Report * • * VERIFY by OLTERSDORF MD, TIMOTHY P. on June 21, 2015 15:25 Printed by: DURAN MD, DONNA M. Page 2of 2 Printed on: 06/22/2015 12:30 (End of Report)