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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