Maples, Daniel Earl Jr.
WR-83,664-01
| Tex. App. | Nov 23, 2015
Case Information

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CELIA M. SAMS ATTORNEY AT LAW P.O. Box 775
Rowlett, TX 75030-0775
Phone: 214-587-7495
Fax: 1-866-214-4350
Email: celiamsams@gmail.com

RECEIVED IN COURT OF CRIMINAL APPEALS

NOV 232015

Abel Acosta. Clerk

November 17, 2015

Honorable Judges Of The Court Of Criminal Appeals Court of Criminal Appeals
P.O.Box 12308, Capital Station
Austin, Texas 78711

Attn: 11.07 Writs

Re: Request for Extension relating to Ex.Parte Daniel Maples Trial Court No. W99 00670, WR-













To the Honorable Judges of the Court of Criminal Appeals:

The purpose of this letter is to request additional time to complete the investigation and prepare findings of fact and conclusions of law in this matter.

The Court master handling these writs has been working diligently on this investigation, however needs additional time for a number of reasons:

  1. The writ application is extensive, including six grounds comprised of twenty-four pages, with a Memorandum of Law consisting of over one hundred pages, and four hundred forty-four pages of exhibits. Further, Applicant has more recently filed additional Motions and Exhibits. His grounds include ineffective assistance of counsel, involuntary plea, and Brady violations, and perjured testimony, among others.
  2. Pursuant to a request by the trial court, on August 6, 2015 this Court granted an extension of time from the original deadline of August 3, 2015 to November 4.

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  1. Pursuant to it's own order, this Court on August 26 abated these proceedings and set a new deadline of November 24.
  2. On September 30, 2015 the Court Reporter made available to the parties a record of the plea and punishment hearings which occurred from April 25- April 28, 2000, consisting of 596 pages. She had re-generated it from tapes, as her notes and exhibits were no longer available.
  3. October 30, 2015, the District Attorney filed their Amended Response, consisting of 57 pages.
  4. On October 31, Applicant filed his Response to State's Amended Response, consisting of 35 pages.
  5. Applicant has since filed Applicant's Proposed Findings, consisting of 14 pages.
  6. The Writ Master has reviewed and analyzed all these documents, but has not had sufficient time to complete her Proposed Findings of Fact and Conclusions of Law and submit them to the trial court and allow time for the trial court to review and approve them before the deadline set by this Court in its order dated August 26, 2015, i.e. Tuesday November 24.

Therefore, I am requesting thirty additional days to complete proposed findings of fact and conclusions of law, and allow the trial court time to review and approve them for submission to this Court.

If you have any questions please contact me. Thank you. Very truly yours,

Celia M. Sams As Writ Master for Judge Dominique Collins Criminal District Court #4