Case Information
*1 PD-1340-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 10/12/2015 10:57:15 PM Accepted 10/15/2015 1:55:15 PM ABEL ACOSTA COURT OF CRIMINAL APPEALS NO. __________________ CLERK ON APPEAL FROM COURT OF APPEALS NO. 01-14-00174-CR
TRIAL COURT CAUSE NO. 1389676 § IN THE TEXAS COURT OF §
vs §
§ THE STATE OF TEXAS § CRIMINAL APPEALS
APPELLANT’S MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW
COMES NOW, STEPHEN CLARK WEBB, Appellant in the above-entitled and numbered cause, and files this, Appellant’s Motion to Extend Time to File Petition for Discretionary Review, and for good cause moves the Court to grant an extension as follows: Appellant intends to file a Petition for Discretionary Review asking the
Court to grant the petition on the grounds that the Court of appeals either decided an important question of state law that has not been, but should be, settled by the Court of Criminal Appeals and which conflicts with applicable decisions of the Court of Criminal Appeals. The deadline for filing a Petition for Discretionary Review in this matter
is October 12, 2015. *2 3. Appellant is seeking a 30 day extension to file his Petition for
Discretionary Review. Appellant seeks additional time to file his Petition for Discretionary
Review for the following reasons:
a) Appellant counsel is the midst of reviewing the record and
responding to an appeal in a three week jury trial on a custody th case currently pending in the 14 Court of Appeals;
b) Appellant’s counsel recently completed a week long trial
modification trial in the District Court of Harris County. c) Appellant has been preparing responses to two motions for
summary judgment involving complex financial matters in a case currently pending in Harris County, Texas There has been no previous extension granted regarding the filing of a Petition for Discretionary Review and the Harris County District Attorney’s Office does not oppose the extension requested.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court grant this Motion and extend the time to file his Petition for Discretionary Review until November 12, 2015.
Respectfully submitted, /s/ John S. Cossum JOHN S. COSSUM TSB #04854500
440 Louisiana, Suite 900 Houston, TX 77002 Telephone: (713) 222-6134 Facsimile: (713) 222-6144 E-Mail: jcossum@cossumlaw.com ATTORNEY FOR APPELLANT, CERTIFICATE OF SERVICE As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d) and (e), I certify that a true and correct copy of the foregoing document has been delivered to the party listed below via electronic transmission on this 12th day of October, 2015.
Eric Kugler
Assistant District Attorney on Appeal
TBC # 796910
Harris County District Attorney’s Office
1201 Franklin, Suite 600
Houston, Texas 77002
Telephone: (713) 755-5826
ATTORNEY FOR APPELLEE,
STATE OF TEXAS
/s/ John S. Cossum JOHN S. COSSUM