PD-0599-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 10/26/2015 10:38:40 AM
October 26, 2015 Accepted 10/26/2015 10:56:03 AM
ABEL ACOSTA
CLERK
CASE NO. PD-0599-15
IN THE TEXAS COURT OF CRIMINAL APPEALS
_______________________________________________________________
THE STATE OF TEXAS
Appellant
v.
MARK TWAIN SIMPSON
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
APPELLEE’S MOTION FOR EXTENSION OF TIME TO
FILE BRIEF ON PETITION FOR DISCRETIONARY REVIEW
BRUCE ANTON
State Bar No. 01274700
ba@sualaw.com
SORRELS, UDASHEN & ANTON
2311 Cedar Springs, Suite 250
Dallas, Texas 75201
(214) 468-8100 (office)
(214) 468-8104 (fax)
Attorney for the Appellee
1
COMES NOW, MARK TWAIN SIMPSON, Appellee herein, and moves
this court to issue an extension of time to file his brief on petition for discretionary
review, and in support thereof would show the court as follows:
I.
Appellee’s brief is currently due on October 23, 2015. Attorney for the
Appellee requests an additional 30 days, until November 22, 2015, top file the
brief.
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. The Appellee plead guilty as terms
of a plea bargain and was sentenced before the judge to twenty five years’
imprisonment.
IV.
No extensions of time to file the brief were previously requested.
V.
The reason for this request is that during the last few weeks counsel has been
working on the following:
1. Petition for Writ of Certiorari in Charles Don Flores v. William
Stephens, Director, in the Supreme Court of the United States.
APPELLEE'S MOTION FOR EXTENSION OF TIME- PAGE 2
2. Petition for Discretionary Review in Cristal Paullett Richardson v.
The State of Texas, case no. PD-1172-15 in the Texas Court of
Criminal Appeals.
3. Appellant’s Reply Brief in Vincent Dewayne Johnson v. The State of
Texas, cause nos. 05-15-00403-CR, 05-15-00404-CR and 05-15-
00405-CR in the Fifth Court of Appeals of Texas.
4. Application for Writ of Habeas Corpus and Memorandum in Support
in Ex Parte Eduardo Enrique Alfaro, in the 401st Judicial District
Court of Collin County, Texas.
VI.
For the reasons set out above, counsel for Mark Twain Simpson will, in
reasonable likelihood, be unable to submit the brief on petition for discretionary
review requested by this court by October 23, 2015. Counsel is asking for an
extension of time of 30 days to file the brief.
WHEREFORE, PREMISES CONSIDERED, Appellant requests this court
to grant an extension of time to file his brief until November 22, 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)
ATTORNEY FOR APPELLEE
APPELLEE'S MOTION FOR EXTENSION OF TIME- 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 22nd day of October, 2015.
/s/ Bruce Anton
BRUCE ANTON
APPELLEE'S MOTION FOR EXTENSION OF TIME- PAGE 4