Case Information

*0 RECEIVED COURT OF CRIMINAL APPEALS 11/24/2015 ABEL ACOSTA, CLERK *1 WR-82,467-01 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/24/2015 11:23:02 AM Accepted 11/24/2015 1:01:55 PM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK FOR THE STATE OF TEXAS AUSTIN, TEXAS

EX PARTE §

§

§ NO. WR-56,666-03 §

DENNIS LEE ALLEN §

IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS AUSTIN, TEXAS

EX PARTE §

§

§ NO. WR-82,467-01 §

STANLEY ORSON MOZEE §

APPLICANT’S MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO TRIAL COURT’S SUPPLEMENTAL FINDINGS OF FACT ON REMAND TO THE HONORABLE PRESIDING JUDGE:

NOW COMES DENNIS LEE ALLEN and STANLEY ORSON MOZEE, Applicants, and submits this Motion for Extension of Time to File Objections to Trial

Court’s Supplemental Findings of Fact on Remand and would show the following:

I. The trial court in these cases has issued the Trial Court’s Supplemental Findings of Fact on Remand. These findings concern an evidentiary hearing held on these writ

applications on October 26-27, 2015.

II. The reporters record of this hearing was prepared and provided to Applicants’ counsel on November 20, 2015. Applicants are working on objections to the trial court’s findings

and request that they be granted until December 8, 2015, to file these objections. This

additional time is necessary based on the length and complexity of this record, as well as the

fact that the due date for these objections has fallen during the Thanksgiving holiday.

III. Counsel for Applicants have conferred with the State’s counsel on this and the State has no objection to this motion.

WHEREFORE, PREMISES CONSIDERED, Applicants pray that this motion be granted.

Respectfully submitted,

/s/ Gary A. Udashen

SORRELS, UDASHEN & ANTON

2311 Cedar Springs Road

Suite 250

Appearing on Behalf of the

Innocence Project of Texas

Counsel for Dennis Lee Allen

/s/ Nina Morrison

NINA MORRISON

INNOCENCE PROJECT, INC.

40 Worth Street, Suite 701

New York, New York 10013

212-364-5340

212-264-5341 fax

/s/ Ezekiel Tyson, Jr.

EZEKIEL TYSON, JR.

THE TYSON LAW FIRM

342 W. Montana Avenue

Counsel for Stanley Orson Mozee

CERTIFICATE OF SERVICE I hereby certify that on the 24th day of November, 2015, a true and correct copy of the above and foregoing Applicants’ Motion for Extension of Time to File Objections to Trial

Court’s Supplemental Findings of Fact on Remand was electronically delivered to the Dallas

County District Attorney’s Office.

/s/ Gary A. Udashen