PD-1340-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/12/2015 12:02:03 AM
Accepted 11/12/2015 2:27:09 PM
ABEL ACOSTA
COURT OF CRIMINAL APPEALS NO. PD-1340-15
CLERK
ON APPEAL FROM COURT OF APPEALS NO. 01-14-00174-CR
TRIAL COURT CAUSE NO. 1389676
STEPHEN CLARK WEBB § IN THE TEXAS COURT OF
§
vs §
§
THE STATE OF TEXAS § CRIMINAL APPEALS
APPELLANT'S MOTION TO EXTEND TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
COMES NOW, STEPHEN CLARK WEBB, Appellant in the above-entitled
and numbered cause, and files this, Appellant's Second Motion to Extend Time to
File Petition for Discretionary Review, and for good cause moves the Court to grant
an extension as follows:
1. Appellant intends to file a Petition for Discretionary Review asking the
Court to grant the petition on the grounds that the Court of appeals
either decided an important question of state law that has not been, but
should be, settled by the Court of Criminal Appeals and which conflicts
with applicable decisions of the Court of Criminal Appeals.
2. The deadline for filing a Petition for Discretionary Review in this matter
is November 11, 2015. ,...„...
FILED IN
COURT OF CRIMINALAPPEALS
November 12, 2015
ABEL ACOSTA, CLERK
3. Appellant is seeking a 2 day extension to file his Petition for
Discretionary Review.
4. Appellant seeks additional time to file his Petition for Discretionary
Review for the following reasons:
a) Appellant's counsel has been in Arizona where he is also licensed
to practice law interviewing witnesses, working on a Joint Pretrial
Statement in preparation for a trial readiness conference
scheduled November 19, 2015 in advance of a projected two
week trial involving multiple defendants scheduled to begin
December 1, 2015.
b) Appallant's counselhas not completed his work in reviewing and
amending the draft PDR prepared in this matter for filing it with
the Court and seeks an additional two days to complete doing so.
5. There has been one previous extension granted regarding the filing of
a Petition for Discretionary Review.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court
grant this Motion and extend the time to file his Petition for Discretionary Review
by two days until November 13, 2015.
Respectfully submitted,
Isi John S. Cossum
JOHN S. COSSUM
TSB #04854500
440 Louisiana, Suite 900
Houston, TX 77002
Telephone: (713)222-6134
Facsimile: (713)222-6144
E-Mail: jcossum@cossumlaw.com
ATTORNEY FOR APPELLANT,
STEPHEN CLARK WEBB
CERTIFICATE OF SERVICE
As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d) and (e),
I certify that a true and correct copy of the foregoing document has been delivered to
the party listed below via electronic transmission on this 11th day of November,
2015.
Eric Kugler
Assistant District Attorney on Appeal
TBC# 796910
Harris County District Attorney's Office
1201 Franklin, Suite 600
Houston, Texas 77002
Telephone: (713) 755-5826
ATTORNEY FOR APPELLEE,
STATE OF TEXAS
Isi John S. Cossum
JOHN S. COSSUM