PD-1466-15 PD-1466-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/12/2015 6:26:43 AM
Accepted 11/12/2015 2:37:51 PM
ABEL ACOSTA
CAUSE NO. ________________________ CLERK
__________________________________________________________________
IN THE COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
__________________________________________________________________
TAYLOR RAE ROSENBUSCH,
Appellant
V.
November 12, 2015 THE STATE OF TEXAS,
Appellee
__________________________________________________________________
Appeal from the 226th District Court of Bexar County, Texas
Trial Court Cause Numbers 2011-CR-11074 and 2011-CR-11075
Court of Appeals Consolidated Cause Number 04-14-00050-CR
__________________________________________________________________
MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
Now comes Taylor Rae Rosenbusch, Appellant, and files this Motion for
Extension of Time to File Petition for Discretionary Review and in support thereof
would show the Court as follows:
1. Appellant intends to file a Petition for Discretionary Review from a
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decision of the Fourth Court of Appeals of Texas.
2. The Case Number and style of the case in the Fourth Court of Appeals
is 04-14-00050-CR, Taylor Rae Rosenbusch v. The State of Texas.
3. The Opinion and Judgment of the Fourth Court of Appeals in Case
Number 04-14-00050-CR was issued on October 14, 2015. No Motion for
Rehearing was filed. Appellant’s Petition for Discretionary Review is due to be
filed on or before November 13, 2015.
4. Appellant seeks an extension of time to file her Petition for
Discretionary Review of thirty (30) days so that the Petition for Discretionary
Review will be due to be filed on December 13, 2015.
5. Counsel for Appellant needs additional time to prepare the Petition for
Discretionary Review. In addition to the regular business of counsel: the
undersigned was in trial during the week of October 19, 2015 in Case Number
2015-CR-0501, State of Texas v. Jacob Estrada, 226th District Court of Bexar
County, Texas; has been engaged in pretrial discovery proceedings in Case
Number 2015-PC-0045, Estate of Radu Ionescu, Bexar County Probate Court No.
One and in Case Number 2014-CI-07119, PEO Consulting v. SWBC Professional
Employer Services, et al, 131st District Court of Bexar County, Texas; and
Summary Judgment proceedings in Case Number 15-03-23,343, Kenneth Hahn v.
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William Paul Gips, et al, 267th District Court of DeWitt County, and Case Number
34173, Templeton v. Williams, et al, District Court of Jasper County.
6. No previous extensions of time to file the Petition for Discretionary
Review have been requested or granted.
WHEREFORE, Appellant respectfully requests that the Court grant this
motion and extend the time for filing Appellant’s Petition for Discretionary
Review for a period of thirty (30) days to December 13, 2015.
Respectfully submitted,
John F. Carroll
Attorney At Law
111 West Olmos Drive
San Antonio, Texas 78212
210/829-7183 - Telephone
210/829-0734 - Facsimile
jcarrollsatx@gmail.com
ATTORNEY FOR APPELLANT,
TAYLOR RAE ROSENBUSCH
By: /s/ John F. Carroll
John F. Carroll
State Bar No. 03888100
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CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the above has been
delivered to the Bexar County District Attorney=s Office, Paul Elizondo Tower,
101 W. Nueva, 4th Floor, San Antonio, Texas 78205 on the 12th day of November,
2015.
/s/ John F. Carroll
John F. Carroll
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Rosenbusch, Taylor Rae
Combined Opinion