PD-0599-15
PD-0599-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/18/2015 3:51:14 PM
Accepted 5/19/2015 4:48:48 PM
ABEL ACOSTA
CLERK
NO. ______________
IN THE TEXAS COURT OF CRIMINAL APPEALS
_______________________________________________________________
MARK TWAIN SIMPSON
Appellant
v.
THE STATE OF TEXAS
Appellee
________________________________________________________________
FROM THE FIFTH COURT OF APPEALS
CAUSE NO.05-14-00618-CR
ON APPEAL FROM CRIMINAL DISTRICT COURT NO. 4
DALLAS COUNTY, TEXAS
TRIAL COURT NO. F-1356596-K
THE HONORABLE DOMINIQUE COLLINS PRESIDING
APPELLANT’S MOTION FOR EXTENSION
OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW
BRUCE ANTON
State Bar No. 01274700
ba@sualaw.com
May 19, 2015
SORRELS, UDASHEN & ANTON
2311 Cedar Springs, Suite 250
Dallas, Texas 75201
(214) 468-8100 (office)
(214) 468-8104 (fax)
1
COMES NOW, MARK TWAIN SIMPSON, Appellant herein, and moves
this court to issue an extension of time to file his 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 no. 05-14-00618-CR,
affirming the conviction, was rendered on April 20, 2015.
II.
The number and style of the case in the District Court is No. F-1356596-K,
State of Texas v. Mark Twain Simpson.
III.
Appellant was convicted of robbery 2nd and sentenced to twenty five years’
imprisonment.
IV.
The present deadline for filing the petition for discretionary review is May
20, 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:
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW - PAGE 2
1. Petition for Writ of Certiorari in Licho Escamilla v. William
Stephens, in the Supreme Court of the United States.
2. Appellant’s Brief on Direct Appeal in Russell Donald Tindell,
II v. State of Texas, case no. 10-15-00016-CR in the Tenth
Court of Appeals of Texas.
3. Oral Argument in Cristal Paullett Richardson v. State of Texas,
case no. 05-14-00523-CR in the Fifth Court of Appeals of
Texas.
4. Jury Trial in Delvecchio Patrick v. State of Texas, case no. F-
1259295 in the 292nd Judicial District Court of Dallas County,
Texas.
WHEREFORE, PREMISES CONSIDERED, Appellant requests this court
to grant an extension of time to file his brief until June 19, 2015.
RESPECTFULLY SUBMITTED,
/s/ BruceAnton
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
ATTORNEY FOR APPELLANT
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 18th day of May, 2015.
/s/ Bruce Anton
BRUCE ANTON
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW - PAGE 4