Isbell, John B.

PD-0469&0470&0471&0472-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 4/27/2015 11:55:10 AM
Accepted 4/27/2015 3:34:47 PM
ABEL ACOSTA
IN THE CLERK
COURT OF CRIMINAL APPEALS

JOHN B. ISBELL, §
APPELLANT §
V. § NO. ___________
April 27, 2015
§
THE STATE OF TEXAS, §
APPELLEE §

STATE’S MOTION TO EXTEND TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW

COMES NOW the State of Texas, by and through Sharen Wilson, the

Tarrant County Criminal District Attorney and files this motion to extend the time

for two weeks to file a petition for discretionary review.

I.

The court of appeals below is the Court of Appeals for the Second Court of

Appeals District. The styles and numbers of the cases in the Fort Worth Court are

Isbell v. State, Nos. 02-14-00124-CR, 02-14-00125-CR, 02-14-00126-CR, and

02-14-00127-CR

II.

On March 26, 2015, the Fort Worth Court issued an opinion reversing the

trial court’s judgments. See Isbell v. State, No. 02-14-00124(-127)-CR, 2015 WL

1407749 (Tex. App.—Fort Worth March 26, 2015) (mem op., not designated for

publication).trial court’s judgment. The State did not file a motion for rehearing.
 III.

The current deadline for filing the State’s petition for discretionary review is

April 27, 2015. The State now requests an extension of 14 days – until May 11,

2015 – to file the State’s petition. The State has not previously requested an

extension of time to file a petition for review in this case.

IV.

This extension is not for the purposes of delay, but rather so that

undersigned counsel may adequately set forth the State’s position in its grounds for

review. The undersigned has been working not only on this PDR, but on the State’s

reply briefs in Gray v. State, No. 02-14-00249-CR; Guzman v. State,

02-14-00297-CR; and a petition for review in Pinkston v. State, No.

02-14-00041-CR.

Wherefore, the State prays that the Court grant an extension of 14 days to

May 11, 2015 for filing the State’s petition for discretionary review.

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 Respectfully submitted,

SHAREN WILSON
Criminal District Attorney
Tarrant County, Texas

DEBRA WINDSOR
Assistant Criminal District Attorney
Chief, Post-Conviction
Tarrant County, Texas

/s/ James Gibson_____________
JAMES GIBSON, Assistant
Criminal District Attorney
401 W. Belknap Street
Fort Worth, Texas 76196-0201
(817) 884-1687
FAX (817) 884-1672
State Bar No. 00787533
COAAppellateAlerts@TarrantCounty.com

CERTIFICATE OF SERVICE

A copy of the State's Motion to Extend Time to File Petition for

Discretionary Review has been e-served to opposing counsel, the Hon. Barry G.

Johnson, Barrygj@aol.com, 2821 E. Lancaster, Fort Worth, Texas 76103, on April

27, 2015.

/s/ James Gibson
JAMES GIBSON
H:\GIBSON.G17\MOTIONS\Isbell; ext to file pdr.docx

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