PD-0208-15 & PD-0209-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
February 26, 2015 Transmitted 2/20/2015 2:02:16 PM
Accepted 2/26/2015 10:01:24 AM
ABEL ACOSTA
NOS. _______________ CLERK
THE STATE OF TEXAS § IN THE COURT OF CRIMINAL
VS. § APPEALS FOR THE STATE
JARQUIS D. JACKSON § OF TEXAS AT AUSTIN
ON APPEAL FROM THE
COUNTY CRIMINAL COURT NO. 3
OF DALLAS COUNTY, TEXAS
IN CAUSE NOS. MB13-62072 & MB13-62071
FOR THE FIFTH DISTRICT OF TEXAS
AT DALLAS IN CAUSE NOS. 05-14-00278-CR & 05-14-00279-CR
APPELLEE’S MOTION TO EXTEND THE TIME FOR FILING THE
APPELLEE’S PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW the Appellee, Jarquis D. Jackson, and respectfully requests
that the time for the filing of the Appellant’s Petition For Discretionary Review in
the above-styled and -numbered cause be extended. In support of this motion the
Appellee would show the Court the following:
I.
Appellee was charged with the misdemeanor offenses of unlawfully
carrying a weapon and possession of marijuana. The trial court granted Appellee’s
motion to suppress and the State appealed. On January 21, 2015, in Opinion Nos.
05-14-00278-CR & 05-14-00279-CR, the Court of Appeals reversed the trial
court’s order granting the motion to suppress.
II.
The Appellee’s Petition For Discretionary Review is due on or before
February 20, 2015. Appellee respectfully requests an extension of time until
March 23, 2015.
III.
No previous extension of time has been requested.
IV.
The Appellant would show the Court that a reasonable explanation exists
for the requested extension. The facts on which the Appellee relies to reasonably
explain the need for this extension are as follows:
Before the undersigned attorney can begin work on the Petition in this case,
the undersigned attorney must prepare and file the briefs in Silva, No. 05-14-
00428-CR; Jackson, No. 05-14-00297-CR; Rico, No. 05-14-00251-CR;
Mikroberts, No. 05-14-00994-CR; Jones, Nos. 05-14-01485-CR & 05-14-01486-
CR; Hunter, No. 05-14-01146-CR; and Leatch, No. 05-14-01496-CR, all of which
have already been granted extensions.
WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully
requests that the time for the filing of the Appellee’s Petition For Discretionary
Review be extended until March 23, 2015.
Respectfully submitted,
Lynn Richardson /s/ Kathleen A. Walsh
Chief Public Defender Kathleen A. Walsh
Dallas County Assistant Public Defender
State Bar No. 20802200
133 N. Riverfront Blvd., LB-2
Dallas, TX. 75207-4399
(214) 653-3550 (telephone)
(214) 653-3539 (fax)
kwalsh@dallascounty.org
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing motion was served on the
Appellate Division of the Dallas County Criminal District Attorney’s Office, on
the 20th day of February, 2015 by electronic transmission to
DCDAAppeals@dallascounty.org.
/s/ Kathleen A. Walsh
Kathleen A. Walsh