PD-0520-15
PD-0520-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/4/2015 11:05:06 AM
Accepted 5/4/2015 3:53:42 PM
CAUSE NO. ______________________ ABEL ACOSTA
CLERK
IN THE COURT OF CRIMINAL APPEALS
FOR THE STATE OF TEXAS
*****
SHARON DENISE JACKSON, Petitioner / Appellant
v.
THE STATE OF TEXAS, Respondent / Appellee
*****
On Petition from a Decision of the Court of Appeals
for the Fifth District of Texas, Dallas Division
in Cause No. 05-14-00283-CR
MOTION TO EXTEND TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TOM PAPPAS
BURLESON PATE & GIBSON, L.L.P.
900 Jackson Street, Suite 330
May 4, 2015
Dallas, Texas 75202
Telephone: (214) 871-4900
Facsimile: (214) 871-7543
Email: tpappas@bp-g.com
COUNSEL FOR
PETITIONER/APPELLANT
SHARON DENISE JACKSON
1
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, SHARON DENISE JACKSON, Petitioner herein, and
Appellant before the Court of Appeals for the Fifth District of Texas at Dallas, Texas,
and files her Motion to Extend Time to File Petition for Discretionary Review.
I.
On April 1, 2015, the Court of Appeals for the Fifth District of Texas, Dallas
Division issued its Judgment and Opinion in Cause 05-14-00283-CR. The
Petitioner/Appellant has not filed a motion for rehearing or en banc reconsideration
with the Court of Appeals for the Fifth District of Texas, Dallas Division.
II.
The deadline for Petitioner/Appellant to file her Petition for Discretionary
Review is May 1, 2015. Undersigned counsel has been in two (2) jury trials in the
30 days since April 1, 2015. Counsel needs additional time to work with the
Petitioner/Appellant in preparing the Petition for Discretionary Review.
III.
Therefore, the Petitioner/Appellant respectfully requests that this Court
pursuant to T.R.App.P. Rule 68.2(c) grant an extension of time to file the Petition for
Discretionary Review to May 18, 2015, fifteen (15) days after the last day for filing
the Petition.
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PRAYER FOR RELIEF
The Petitioner respectfully prays that this Court grant this Motion to Extend
Time to File Petition for Discretionary Review to May 18, 2015.
Respectfully submitted,
BURLESON PATE & GIBSON, L.L.P.
/s/ Tom Pappas
_________________________________
TOM PAPPAS
TEXAS BAR CARD NO.15455300
900 Jackson Street, Suite 330
Dallas, Texas 75202
Telephone: (214) 871-4900
Facsimile: (214) 871-7543
Email: tpappas@bp-g.com
COUNSEL FOR
PETITIONER/APPELLANT
SHARON DENISE JACKSON
CERTIFICATE OF SERVICE
This will certify that a copy of the foregoing was delivered by placing same in
the United States Mail via U.S. First Class mail to the following:
Mr. G. Brian Garrison Ms. Lisa M. McMinn
Dallas County District Attorney State Prosecuting Attorney
133 N. Riverfront Blvd., LB 19 P.O. Box 13046
Dallas, Texas 75207 Austin, Texas 78711
DATED the 1st day of May, 2015.
/s/ Tom Pappas
_________________________________
TOM PAPPAS
3