Case Information

*1 PD-0823&0824-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/2/2015 10:46:34 AM Accepted 7/2/2015 3:36:06 PM ABEL ACOSTA NOS. ___________________ and _____________________ CLERK RICHARD DOUGLAS BAILEY § IN THE COURT OF CRIMINAL APPEALS

v. § STATE OF TEXAS

THE STATE OF TEXAS § AUSTIN, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT:

NOW COMES, the Appellant, RICHARD DOUGLAS BAILEY, and moves for an extension of time to file the Appellant’s Petition for Discretionary Review in these cases, and in support thereof would show the following:

I. a. These cases arise out of Criminal District Court No. 1 of Dallas County, Texas under

Cause Nos. F12-34478-H and F12-34479-H, styled State of Texas v. Richard Douglas Bailey. They are also pending in the Dallas Court of Appeals under case numbers 05-14-00885-CR and 05-14-00886-CR.

b. Appellant was convicted of Theft of a Firearm in cause number F12-34478-H and

sentenced to 1 year state jail. Appellant was also convicted of Unlawful Possession of a Firearm in Weapon Free Zone in cause number F12-34479-H and sentenced to 4 years imprisonment in the Texas Department of Criminal Justice. The judgment date was June 17, 2014. On June 2, 2015, the Court of Appeals affirmed the convictions.

c. The deadline for filing the Appellant’s Petition for Discretionary Review is July 2, d. Appellant requests an extension until August 2, 2015, to file the Petition for

Discretionary Review. e. The reason for this request is that, in the last few weeks, counsel has been working

on the following:

1. Reply Brief in Ex Parte Micah Tutton , No. 10-14-00360-CR, in the Tenth

Court of Appeals. 2. Brief in Mark Edwin Guida v. State of Texas , No. 05-14-01626-CR, in the

Fifth Court of Appeals. 3. Objections to Findings, Conclusions and Recommendation of United States

Magistrate Judge in William Luck v. United States , No. 3:14-CV-1989-B, in the United States District Court for the Northern District of Texas.

4. Reply to State’s Response to Application for Writ of Habeas Corpus in Ex

Parte Charles Atterbury , No. W401-80045-08-HC, in the 401st District Court of Collin County, Texas. Brief in Tom Iles White III v. State of Texas , No. 05-14-01359-CR, in the

Fifth Court of Appeals. WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays that this Motion be granted.

Respectfully submitted, Bar Card No. 24079086 SORRELS, UDASHEN & ANTON 2311 Cedar Springs Road Suite 250

Dallas, Texas 75201 214-468-8100

214-468-8104 fax

ATTORNEY FOR APPELLANT *3 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Motion for Extension of Time to File Appellant’s Petition for Discretionary Review was electronically delivered to the Dallas County District Attorney’s Office and to the State Prosecuting Attorney, on this the 2nd day of July, 2015.