WR-83,664-01
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/18/2015 10:29:38 AM
CELIA M. SAMS Accepted 11/18/2015 12:53:13 PM
ABEL ACOSTA
ATTORNEY AT LAW CLERK
P.O. Box 775
Rowlett, TX 75030-0775 RECEIVED
COURT OF CRIMINAL APPEALS
Phone: 214-587-7495 11/18/2015
ABEL ACOSTA, CLERK
Fax: 1-866-214-4350
Email: celiamsams@gmail.com
November 17, 2015
Honorable Judges Of The Court Of Criminal Appeals
Court of Criminal Appeals
P.O.Box 12308, Capital Station
Austin, Texas 78711
Attn: 11.07 Writs
Re: Request for Extension relating to Ex Parte Daniel Maples
Trial Court No W99 00670, WR---
To the Honorable Judges of the Court of Criminal Appeals:
The purpose of this letter is to request additional time to complete the
investigation and prepare findings of fact and conclusions of law in this matter.
The Court master handling these writs has been working diligently on this
investigation, however needs additional time for a number of reasons:
1. The writ application is extensive, including six grounds comprised of
twenty-four pages, with a Memorandum of Law consisting of over one
hundred pages, and four hundred forty-four pages of exhibits.
Further, Applicant has more recently filed additional Motions and
Exhibits. His grounds include ineffective assistance of counsel,
involuntary plea, and Brady violations, and perjured testimony, among
others.
2. Pursuant to a request by the trial court, on August 6, 2015 this Court
granted an extension of time from the original deadline of August 3, 2015
to November 4.
3. Pursuant to it’s own order, this Court on August 26 abated these
proceedings and set a new deadline of November 24.
4. On September 30, 2015 the Court Reporter made available to the parties
a record of the plea and punishment hearings which occurred from April
25- April 28, 2000, consisting of 596 pages. She had re-generated it
from tapes, as her notes and exhibits were no longer available.
5. October 30, 2015, the District Attorney filed their Amended Response,
consisting of 57 pages.
6. On October 31, Applicant filed his Response to State’s Amended
Response, consisting of 35 pages.
7. Applicant has since filed Applicant’s Proposed Findings, consisting of 14
pages.
8. The Writ Master has reviewed and analyzed all these documents, but has
not had sufficient time to complete her Proposed Findings of Fact and
Conclusions of Law and submit them to the trial court and allow time for
the trial court to review and approve them before the deadline set by this
Court in its order dated August 26, 2015, i.e. Tuesday November 24.
Therefore, I am requesting thirty additional days to complete proposed
findings of fact and conclusions of law, and allow the trial court time to review and
approve them for submission to this Court.
If you have any questions please contact me.
Thank you.
Very truly yours,
“s” Celia M. Sams
Celia M. Sams
As Writ Master for
Judge Dominique Collins
Criminal District Court #4