Case Information
*1 WR-73,697-06,07,08,09 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/18/2015 10:58:45 PM Accepted 8/19/2015 8:28:42 AM ABEL ACOSTA WRIT NO. W06-‐00445-‐K(B), W06-‐00448-‐K(B), W06-‐00450-‐K(B) and CLERK W06-‐00453-‐K(B) WR-‐73, 697-‐06, 07, 08, 09 In the Texas Court of Criminal Appeals At Austin From the CDC No. 4 Dallas County, Texas EX PARTE RAUL DAVID JACKSON 11.07 Writ MOTION FOR EXTENSION OF TIME TO FILE FINDING OF FACTS AND
CONCLUSIONS OF LAW Bruce C. Kaye 2309 Boll St.
Dallas, TX 75204 (214) 722-‐7438 APPOINTED WRIT MASTER, CDC 4
I. On or about November 26, 2014, the undersigned was appointed as Writ Master by the Honorable Judge Dominique Collins, Criminal District Court No. 4, Dallas County, Texas. The Court’s Finding of Fact and Conclusions of Law are now due on August 19, 2015, per this Court’s Order dated on or about May 19, 2015.
II.
The issues to be resolved are as follows:
a. Is Applicant’s judgment and sentence void;
b. Does Applicant’s sentence violate double jeopardy
c. Was Applicant’s plea involuntary; and
d. Did Applicant receive ineffective assistance of trial and appellate
counsel.
III. The undersigned appointed Writ Master has been involved in numerous Appellate and trial matters in both state and federal court. Currently, Counsel is long medicare fraud case involving over 1200 pages of transcripts. Counsel is also completing an appointed sentencing memorandum in a federal case involving the fraudulent filing of 30 million dollars of tax claims with the IRS (with extensive discovery to review). Counsel is also set for an appointed murder trial in state court for the first week of October and also set for a federal trial in October involving 4 terabytes of discovery (medical clinic allegedly prescribing hydrocodone for everyone who asks).
IV. An additional 120 days is required in order to properly read Applicant’s paperwork, review the State’s response, research the issues and thereafter prepare the Finding of Facts and Conclusions of Law for the Court.
WHEREFORE, PREMISES CONSIDERED , the appointed Writ Master for CDC 4, Dallas County, Texas, prays this Court grant his Motion for Extension of Time to File Finding of Facts and Conclusions of Law and set a new due date for 120 days from the current due date of August 19, 2015.
Respectfully submitted, /s/ Bruce C. Kaye Bruce C. Kaye TBN. 00784374 Appointed Writ Master, CDC 4 2309 Boll St. Dallas, Texas 75204 (214) 722-‐7438 office (866) 649-‐8757 fax bruce@brucekaye.com