PD-1172-15
PD-1172-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 9/9/2015 3:46:30 PM
Accepted 9/14/2015 11:49:04 AM
ABEL ACOSTA
CASE NO. ______________ CLERK
IN THE TEXAS COURT OF CRIMINAL APPEALS
_______________________________________________________________
CRISTAL PAULLETT RICHARDSON
Appellant
v.
THE STATE OF TEXAS
Appellee
________________________________________________________________
FROM THE FIFTH COURT OF APPEALS
CAUSE NO. 05-14-00523-CR
ON APPEAL FROM CRIMINAL DISTRICT COURT NO. 6
DALLAS COUNTY, TEXAS
TRIAL COURT NO. F-1300479-X
THE HONORABLE JEANINE HOWARD PRESIDING
APPELLANT’S MOTION FOR EXTENSION
OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW
BRUCE ANTON
State Bar No. 01274700
ba@sualaw.com
SORRELS, UDASHEN & ANTON
2311 Cedar Springs, Suite 250
Dallas, Texas 75201
(214) 468-8100 (office)
September 14, 2015 (214) 468-8104 (fax)
Attorney for Appellant
1
COMES NOW, CRISTAL P. RICHARDSON, Appellant herein, and moves
this court to issue an extension of time to file her petition for discretionary review,
and in support thereof would show the court as follows:
I.
The opinion of the Fifth Court of Appeals in cause number 05-14-00523-
CR, affirming the conviction, was rendered on August 11, 2015.
II.
The number and style of the case in the District Court is No. F-1300479-X
State of Texas v. Cristal Paullett Richardson.
III.
Appellant was convicted of murder and sentenced to life imprisonment.
IV.
The present deadline for filing the petition for discretionary review in this
matter is September 10, 2015.
V.
No extensions of time to file the brief were previously requested.
VI.
The reason for this request is that during the last few weeks counsel has been
working on the following:
1. Petition for Discretionary Review in Fredrick Carson v. The State of
Texas, case no. PD-0809-15 in the Texas Court of Criminal Appeals.
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW - PAGE 2
2. Petition for Discretionary Review in Oczaveone Jackson v. The State of
Texas, case no. PD-0964-15 in the Texas Court of Criminal Appeals.
3. Appellant’s Reply Brief in Adolph Junior Menjivar v. The State of
Texas, case no 05-14-01028-CR in the Fifth Court of Appeals of Texas.
4. Petition for Certiorari in William Earl Rayford v. William Stephens, in
the Supreme Court of the United States
For the reasons set out above, counsel for Cristal P. Richardson will, in
reasonable likelihood, be unable to submit the petition requested by this court by
September 10, 2015. Counsel is asking for an extension of time of 30 days, or until
approximately October 10, 2015.
WHEREFORE, PREMISES CONSIDERED, Appellant requests this court
to grant an extension of time to file his petition for discretionary review until
October 10, 2015.
RESPECTFULLY SUBMITTED,
/s/ Bruce Anton
BRUCE ANTON
Texas State Bar No. 01274700
SORRELS, UDASHEN & ANTON
2311 Cedar Springs #250
Dallas, Texas 75201
(214) 468-8100
(214) 468-8104 (fax)
ba@sualaw.com
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW - PAGE 3
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the above entitled motion
for extension of time was electronically served to the Appellate Division of the
Dallas County District Attorney’s Office and to the State Prosecuting Attorney on
this 9th day of September, 2015.
/s/ Bruce Anton
BRUCE ANTON
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW - PAGE 4