Case Information
*1 PD-1420&1421&1422-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/4/2015 12:46:09 PM Accepted 11/5/2015 2:46:45 PM ABEL ACOSTA No. _____________________ 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:
That Appellant took his appeal from the 43 rd 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.
On October 1, 2015, in an unpublished opinion, the Court of Appeals affirmed the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.
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.
That Appellant is incarcerated.
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.
Jack V. Strickland
Respectfully Submitted, _______________________________ 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 Jack V. Strickland District Attorney Edward Lewallen concurring the foregoing motion. Mr. Lewallen has no
objected to the granting of the motion.
______________________________ Jack V. Strickland Certificate of Service Jack V. Strickland 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