PD-1155-16 PD-1155-16
COURT OF CRIMINAL APPEALS
In the Texas Court of Criminal Appeals AUSTIN, TEXAS
Transmitted 9/26/2016 12:00:00 AM
On Petition for Discretionary Review
Accepted 9/26/2016 4:03:12 PM
ABEL ACOSTA
from the Fifth Court of Appeals; Cause CLERK
Number 05-16-570-CR, affirming the
Ex Parte Michael Dwain Bradshaw denial of habeas corpus in Cause
Number F14-49105-J
from the 3rd District Court of Dallas
County, Texas.
Motion to Extend Time to File PDR
To the Honorable Court of Criminal Appeals:
Appellant moves to extend the time for her to file his Petition for
Discretionary Review, and would show:
The Fifth Court of Appeals entered judgment in Mr. Michael
Dwain Bradshaw’s case, styled Ex Michael Dwain Bradshaw, on August
23, 2016.
Mr. Bradshaw did not move for rehearing.
Counsel told Mr. Bradshaw that he would file a petition for
discretionary review.
The deadline for Mr. Bradshaw to file his Petition for Discretionary
Review was September 22, 2016.
Counsel lost track of this deadline. Counsel’s failure to file is not
attributable to Mr. Bradshaw.
Counsel has been fully occupied briefing other free-speech cases.
September 26, 2016
Mr. Bradshaw seeks an additional sixty days, until November 22,
2016, to file his Petition for Discretionary Review.
Mr. Bradshaw has sought no previous extensions.
Certificate of Service
A copy of this motion will be delivered to Jaclyn O’Connor Lambert,
the attorney for the State in the Court of Appeals; and to Lisa
McMinn, the State Prosecuting Attorney, by the efiling system.
Thank you,
________________________
Mark Bennett
SBN 00792970
Bennett & Bennett
917 Franklin Street, Fourth Floor
Houston, Texas 77002
713.224.1747
mb@ivi3.com
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