Woodard, Brandon

WR-65,038-02 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/12/2015 3:11:58 PM Accepted 8/12/2015 3:30:04 PM ABEL ACOSTA CAUSE NO. WR-65,038-02 CLERK IN THE COURT OF CRIMINAL APPEALS RECEIVED COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS 8/12/2015 AT AUSTIN ABEL ACOSTA, CLERK __________________________________________________ CAUSE NO. W00-53218-M(C) EX PARTE § IN THE 194TH JUDICIAL § § DISTRICT COURT § BRANDON WOODARD § DALLAS COUNTY, TEXAS ________________________________________________ MOTION FOR EXTENSION OF TIME TO FILE FINDINGS OF FACT AND CONCLUSIONS OF LAW _________________________________________________ COMES NOW, Bruce Anton, acting as court appointed attorney in this cause, and moves this court to issue an extension of time to perfect his claim, and in support thereof would show the court as follows: I. This writ of habeas corpus is currently pending in the194th Judicial District Court of Dallas County, Texas. An order was issued on October 1, 2014 ordering the trial court to make findings of fact and conclusions of law by January 29, 2015 in regard to Applicant’s claim that he is actually innocent. A notice from the Court of Criminal Appeals was sent on July 30, 2015, notifying the court that to date, a supplemental record including the finding of fact has not been filed. II. The undersigned attorney was appointed as his counsel at the request of the conviction integrity unit of the Dallas District Attorney’s office. The investigation of the claim involves locating a co-defendant who has been released from prison. The witness’s residence has been located, but counsel’s investigator has been unable to contact the witness himself. III. Counsel requests that the court grant him an additional 90 days from this date to complete the investigation. VI. The facts relied upon to show good cause for this request for extension are recited above. WHEREFORE, PREMISES CONSIDERED, the undersigned attorney requests this court to grant an extension of time of 90 days to complete the prosecution of this writ. RESPECTFULLY SUBMITTED, /s/ Bruce Anton BRUCE ANTON State Bar No. 01274700 SORRELS UDASHEN & ANTON 2311 Cedar Springs, Suite 250 Dallas, Texas 75201 214/468-8100 214/468-8104 (fax) CERTIFICATE OF SERVICE This is to certify that a true and correct copy of Appellant’s motion for extension was served to the Dallas County District Attorney’s Office, Appellate Division, via email through the e-filing. /s/ Bruce Anton BRUCE ANTON