PD-1340-15 PD-1340-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 10/12/2015 10:57:15 PM
Accepted 10/15/2015 1:55:15 PM
ABEL ACOSTA
COURT OF CRIMINAL APPEALS NO. __________________ CLERK
ON APPEAL FROM COURT OF APPEALS NO. 01-14-00174-CR
TRIAL COURT CAUSE NO. 1389676
STEPHEN CLARK WEBB § IN THE TEXAS COURT OF
§
vs §
§
THE STATE OF TEXAS § CRIMINAL APPEALS
APPELLANT’S MOTION TO EXTEND TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
COMES NOW, STEPHEN CLARK WEBB, Appellant in the above-entitled
and numbered cause, and files this, Appellant’s Motion to Extend Time to File
Petition for Discretionary Review, and for good cause moves the Court to grant an
extension as follows:
1. Appellant intends to file a Petition for Discretionary Review asking the
Court to grant the petition on the grounds that the Court of appeals
either decided an important question of state law that has not been, but
should be, settled by the Court of Criminal Appeals and which conflicts
with applicable decisions of the Court of Criminal Appeals.
2. The deadline for filing a Petition for Discretionary Review in this matter
is October 12, 2015.
October 15, 2015
3. Appellant is seeking a 30 day extension to file his Petition for
Discretionary Review.
4. Appellant seeks additional time to file his Petition for Discretionary
Review for the following reasons:
a) Appellant counsel is the midst of reviewing the record and
responding to an appeal in a three week jury trial on a custody
case currently pending in the 14th Court of Appeals;
b) Appellant’s counsel recently completed a week long trial
modification trial in the District Court of Harris County.
c) Appellant has been preparing responses to two motions for
summary judgment involving complex financial matters in a case
currently pending in Harris County, Texas
5. There has been no previous extension granted regarding the filing of a
Petition for Discretionary Review and the Harris County District
Attorney’s Office does not oppose the extension requested.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court
grant this Motion and extend the time to file his Petition for Discretionary Review
until November 12, 2015.
Respectfully submitted,
/s/ John S. Cossum
JOHN S. COSSUM
TSB #04854500
440 Louisiana, Suite 900
Houston, TX 77002
Telephone: (713) 222-6134
Facsimile: (713) 222-6144
E-Mail: jcossum@cossumlaw.com
ATTORNEY FOR APPELLANT,
STEPHEN CLARK WEBB
CERTIFICATE OF SERVICE
As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d) and (e),
I certify that a true and correct copy of the foregoing document has been delivered to
the party listed below via electronic transmission on this 12th day of October, 2015.
Eric Kugler
Assistant District Attorney on Appeal
TBC # 796910
Harris County District Attorney’s Office
1201 Franklin, Suite 600
Houston, Texas 77002
Telephone: (713) 755-5826
ATTORNEY FOR APPELLEE,
STATE OF TEXAS
/s/ John S. Cossum
JOHN S. COSSUM
Webb, Stephen Clark
Combined Opinion