Case Information
*0 RECEIVED COURT OF CRIMINAL APPEALS 11/24/2015 ABEL ACOSTA, CLERK *1 WR-82,467-01 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/24/2015 11:23:02 AM Accepted 11/24/2015 1:01:55 PM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK FOR THE STATE OF TEXAS AUSTIN, TEXAS
EX PARTE §
§
§ NO. WR-56,666-03 §
DENNIS LEE ALLEN §
IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS AUSTIN, TEXAS
EX PARTE §
§
§ NO. WR-82,467-01 §
STANLEY ORSON MOZEE §
APPLICANT’S MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO TRIAL COURT’S SUPPLEMENTAL FINDINGS OF FACT ON REMAND TO THE HONORABLE PRESIDING JUDGE:
NOW COMES DENNIS LEE ALLEN and STANLEY ORSON MOZEE, Applicants, and submits this Motion for Extension of Time to File Objections to Trial
Court’s Supplemental Findings of Fact on Remand and would show the following:
I. The trial court in these cases has issued the Trial Court’s Supplemental Findings of Fact on Remand. These findings concern an evidentiary hearing held on these writ
applications on October 26-27, 2015.
II. The reporters record of this hearing was prepared and provided to Applicants’ counsel on November 20, 2015. Applicants are working on objections to the trial court’s findings
and request that they be granted until December 8, 2015, to file these objections. This
additional time is necessary based on the length and complexity of this record, as well as the
fact that the due date for these objections has fallen during the Thanksgiving holiday.
III. Counsel for Applicants have conferred with the State’s counsel on this and the State has no objection to this motion.
WHEREFORE, PREMISES CONSIDERED, Applicants pray that this motion be granted.
Respectfully submitted,
/s/ Gary A. Udashen
SORRELS, UDASHEN & ANTON
2311 Cedar Springs Road
Suite 250
Appearing on Behalf of the
Innocence Project of Texas
Counsel for Dennis Lee Allen
/s/ Nina Morrison
NINA MORRISON
INNOCENCE PROJECT, INC.
40 Worth Street, Suite 701
New York, New York 10013
212-364-5340
212-264-5341 fax
/s/ Ezekiel Tyson, Jr.
EZEKIEL TYSON, JR.
THE TYSON LAW FIRM
342 W. Montana Avenue
Counsel for Stanley Orson Mozee
CERTIFICATE OF SERVICE I hereby certify that on the 24th day of November, 2015, a true and correct copy of the above and foregoing Applicants’ Motion for Extension of Time to File Objections to Trial
Court’s Supplemental Findings of Fact on Remand was electronically delivered to the Dallas
County District Attorney’s Office.
/s/ Gary A. Udashen