PD-1420&1421&1422-15 COURT
PD-1420&1421&1422-15
OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/4/2015 12:46:09 PM
Accepted 11/5/2015 2:46:45 PM
No. _____________________ ABEL ACOSTA
CLERK
WILLIAM BRUCE SENN, JR., § IN THE
APPELLANT §
§
V. § TEXAS COURT OF
§
THE STATE OF TEXAS, §
APPELLEE § CRIMINAL APPEALS
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF THE TEXAS COURT OF CRIMINAL APPEALS:
COMES NOW, William Bruce Senn, Jr, Appellant in the above-styled and numbered
cause, by and through his court appointed attorney of record, Jack V. Strickland and files this
motion for extension of time to file petition for discretionary review. In support of said motion,
Appellant shows as follows:
1.
That Appellant took his appeal from the 43rd Judicial District Court of Parker County,
Texas, to the Second Court of Appeals sitting in Fort Worth, Texas. In his appeal, Appellant
raised a a single point of error arising from the three felony convictions which formed the basis
of that appeal.
2.
On October 1, 2015, in an unpublished opinion, the Court of Appeals affirmed the
judgments of the trial court. Appellant did not request a rehearing.
November 5, 2015
3.
That Appellant’s petition for discretionary review is accordingly due on Monday,
November 2, 2015, the first business day following the expiration of 30 days after the day the
court of appeals’ judgment was rendered. R. 68. 2 (a), TEX. R. APP. PROC.
4.
That Appellant now timely requests an extension of time in which to file his petition.
Appellant requests that this court order the filing of his petition not later than Wednesday,
November 25, 2015, an extension of 23 days. R. 68. 2 (C), TEX. R. APP. PROC.
5.
That Appellant’s counsel is involved in a significant number of criminal cases in both
State and Federal court, including appeals and trial matters that include significant felony
allegations.
6.
That this is Appellant’s first motion for extension of time for the filing of a petition for
discretionary review.
7.
That Appellant is incarcerated.
8.
That this motion is not merely for purposes of delay, but in order that justice may be
done.
WHEREFORE, PREMISES CONSIDERED, Appellants prays that the Court grant this
motion and order that Appellant’s petition for discretionary review be filed not later than
November 25, 2015.
Respectfully Submitted,
Jack V. Strickland
_______________________________
JACK V. STRICKLAND
ATTORNEY FOR DEFENDANT
112 Hogle Street
Weatherford, Texas 76086
817.594.2161 (phone)
817.594.2160 (fax)
jvstrickland1943@gmail.com
State Bar No. 19397000
Certificate of Conference
On October 30, 2015, a telephone conference was held with Parker County Assistant
District Attorney Edward Lewallen concurring the foregoing motion. Mr. Lewallen has no
objected to the granting of the motion.
Jack V. Strickland
______________________________
Jack V. Strickland
Certificate of Service
On October 30, 2015, a true and correct copy of the foregoing motion was emailed to Mr.
Lewallen at edward.lewallen@outlook.com.
Jack V. Strickland
______________________________
Jack V. Strickland