PD1396-14
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
February 27, 2015 Transmitted 2/26/2015 4:35:09 PM
Accepted 2/26/2015 4:37:10 PM
ABEL ACOSTA
CLERK
Cause No. PD-1396-14
COURT OF CRIMINAL APPEALS
OF TEXAS
JON THOMAS FORD, §
Petitioner, §
§ FROM THE
FOURTH COURT OF
vs. §
APPEALS
§ SAN ANTONIO, TEXAS
THE STATE OF TEXAS, § 04-12-00317-CR
Respondent. §
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL
APPEALS:
NOW COMES Petitioner, JON THOMAS FORD, by and through his
undersigned counsel, and files this Unopposed Motion for Extension of Time to
file his Brief, pursuant to Rule 38.6(d) of the Texas Rules of Appellate Procedure.
Appellant respectfully requests a forty (40) day extension to and including April
15, 2015. This is Petitioner’s first motion for extension of time to file his brief. In
support of this motion Petitioner would show as follows:
1. Petitioner’s brief is currently due on March 6, 2015.
2. Counsel has conferred with Jay Brandon, Bexar County Assistant District
Attorney, and he dose not oppose this motion.
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Undersigned Counsel has the following judicial conflicts:
3. Undersigned counsel was in Court for a Motions hearing on February 4,
2015 and February 6, 2015 in United States of America v. Wissam Allouche,
Cause No. 13-CR-00420 in the United States District Court for the Western
District of Texas, when the Order granting Petitioner’s Discretionary
Review and Notice of Brief deadline was filed in this case.
4. Undersigned counsel then started Trial on February 9, 2015 in United States
of America v. Wissam Allouche, Cause No. 13-CR-00420 in the United
States District Court for the Western District of Texas. The Trial concluded
on February 20, 2015.
5. Undersigned counsel had out of town meetings scheduled on February 23,
2015 in regard to State of Texas v. Joseph Fredrick Karr, Cause No. D-1-
DC-14-302194 in the 147th District Court of Travis County, Texas. Wherein
she represents a victim in a capital murder case.
6. Undersigned counsel has a Plea deadline on March 9, 2015 in United States
of America vs. Kunlin Hsieh, Cause No. 14-CR-00641 in the United States
District Court for the Western District of Texas. An ITAR and EAR case.
7. Undersigned counsel is set for Docket Call and Rearraignment on March 12,
2015 in United States of America vs. Kunlin Hsieh, Cause No. 14-CR-00641
in the United States District Court for the Western District of Texas.
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8. Undersigned Counsel is preparing a Motion for New Trial and Motion for
Judgment not Withstanding the Verdict in United States of America v.
Wissam Allouche, Cause No. 13-CR-00420 in the United States District
Court for the Western District of Texas, that is due on March 13, 2015. One
Count was acquitted and the government’s theory on Count Three varied
fatally from the indictment as well as the Court declined to provide a proper
and requested jury instruction to the jury on Count Two and a proper and
requested note answer on Count Three.
9. Undersigned counsel is set for Jury Selection and Trial on March 16, 2015 in
United States of America vs. Kunlin Hsieh, Cause No. 14-CR-00641 in the
United States District Court for the Western District of Texas.
10. Undersigned counsel is preparing Findings of Fact and Conclusions of Law
in a Writ of Habeas Corpus proceeding in Ex Parte James R. Hiatt, Cause
No. 2006-CR-2741-W3 in the 144th Judicial District Court, Bexar County,
San Antonio, Texas.
11. Undersigned counsel is set for Jury Selection and Trial on March 23, 2015
in United States of America v. Oguzhan Aydin, Cause No. 12-CR-00221 in
the United States District Court for the Northern District of Georgia.
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12. Undersigned counsel is preparing for and is set for a Motions hearing on
March 31, 2015 in Ex Parte James Moore, Cause No 00-188-K26 in the 26th
Judicial District Court, Williamson County, Texas.
13. Undersigned counsel is investigating discovery and preparing replies to
responses to pretrial motions in United States of America v. Curtis DeBerry,
Cause No. 14-CR-00524 in the United States District Court for the Western
District of Texas. The Plea Deadline is on April 3, 2015 and a Motions
Hearing is set on April 8, 2015.
Undersigned counsel has the following professional conflicts:
14. Undersigned counsel is Chair of the American Bar Association’s Criminal
Justice Section. She is obligated and has pre-arranged plans to speak at the
Section’s National Summit on Collateral Consequences on February 27,
2015 in Washington, D.C. and also at the 29th Annual National Institute on
White Collar Crime Seminar on March 4-6, 2015 in New Orleans,
Louisiana.
15. Undersigned counsel also has pre-arranged plans and obligations to teach at
the National Association of Criminal Defense Lawyers White Collar Crime
Defense College on March 12-15, 2015 in St. Pete Beach, Florida.
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16. Undersigned counsel is participating in and has pre-arranged plans to attend
the Hadi Hearing on March 23-28, 2015 as an NGO observer in Guantanamo
Bay, Cuba.
PRAYER FOR RELIEF
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays
that this Honorable Court grant him an additional forty (40) days to and including
April 15, 2015 to file his brief and for any other relief under this Court’s
supervisory power.
Respectfully submitted:
CYNTHIA E. ORR
Bar No. 15313350
GOLDSTEIN, GOLDSTEIN & HILLEY
310 S. St. Mary’s St.
29th Floor Tower Life Building
San Antonio, Texas 78205
210-226-1463
210-226-8367 facsimile
By:___/s/ Cynthia E. Orr______
CYNTHIA E. ORR
Attorney for Petitioner,
JON THOMAS FORD
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CERTIFICATE OF SERVICE
I hereby certify that a copy of the above foregoing Unopposed Motion for
Extension of Time to File Brief has been served via e-mail through the EFSP
Electronic Filing System, to Jay Brandon, Assistant Criminal District Attorney,
jay.brandon@bexar.org, on this the 26th day of February, 2015.
By: _/s/Cynthia E. Orr________
CYNTHIA E. ORR
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