Case Information
*1 PD-1340-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/12/2015 12:02:03 AM Accepted 11/12/2015 2:27:09 PM ABEL ACOSTA COURT OF CRIMINAL APPEALS NO. PD-1340-15 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 Second 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 November 11, 2015. ,...„... FILED IN
COURT OF CRIMINALAPPEALS November 12, 2015 ABEL ACOSTA, CLERK *2 3. Appellant is seeking a 2 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's counsel has been in Arizona where he is also licensed
to practice law interviewing witnesses, working on a Joint Pretrial Statement in preparation for a trial readiness conference scheduled November 19, 2015 in advance of a projected two week trial involving multiple defendants scheduled to begin December 1, 2015.
b) Appallant's counselhas not completed his work in reviewing and
amending the draft PDR prepared in this matter for filing it with the Court and seeks an additional two days to complete doing so. There has been one previous extension granted regarding the filing of
a Petition for Discretionary Review. WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court grant this Motion and extend the time to file his Petition for Discretionary Review by two days until November 13, 2015.
Respectfully submitted, Isi 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 11th day of November,
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
Isi John S. Cossum JOHN S. COSSUM