Adams, Karen Ladell

Opinion

PD-0293-15

PD-0293-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 3/18/2015 3:22:53 PM Accepted 3/19/2015 9:41:12 AM CASE NO. ABEL ACOSTA CLERK

In the Court of Criminal Appeals Austin, Texas

KAREN LADELL ADAMS

Petitioner

March 19, 2015 V.

STATE OF TEXAS

Respondent

Appealed from the Second Court of Appeals Fort Worth, Texas

Court of Appeals Cause No. 02-13-00184-CR

MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

NOW COMES, Karen Ladell Adams, petitioner, who makes and files the following motion for extension of time in which to file her petition for discretionary review, and in support thereof would respectfully show:

I.

CERTIFICATE OF CONFERENCE This is to certify that a conference was held with the state’s attorney regarding the merits of this motion and the requested relief. Counsel for the state advised that she did not oppose the requested relief.

II.

On February 5, 2015, the second court of appeals sitting in Fort Worth, Texas handed down its opinion and judgment affirming petitioner’s conviction and sentence in cause number 02-13-00184-CR, styled Karen Ladell Adams v. State of Texas. In addition to this petition for discretionary review, undersigned counsel also represents Karen Ladell Adams’ son, Gordon Ray Lewis, and is in the process of preparing and filing a petition for discretionary review in case number PD-0173-15, styled Gordon Ray Lewis v. State of Texas.

III.

The petition for discretionary review in this matter was due March 9, 2015. Petitioner seeks an additional nine days in which to file her petition for discretionary review.

IV.

Good cause exists for this extension. As stated above, counsel for petitioner also represents Gordon Ray Lewis in his appeal before this Court, and the petition for discretionary review is due in that case on March 19, 2015. This case and Gordon Ray Lewis’ case are somewhat intertwined, in that Karen Ladell Adams was convicted of retaliation by threat for statements made after the indictment of her son for capital murder. Counsel for Adams miscalculated the due date for the petition for discretionary review in this matter. This miscalculation was inadvertant and was not deliberate or the result of conscious indifference.

V.

No previous extension to file a petition for discretionary review has been requested or granted. No further extensions will be necessary because the petition for discretionary review is being filed contemporaneously with this motion.

VI.

Petitioner Karen Ladell Adams is no longer incarcerated in the Texas Department of Criminal Justice, institutional division, but is now on parole.

WHEREFORE, PREMISES CONSIDERED, Karen Ladell Adams prays that her motion for extension to file her petition for discretionary review in the above styled and numbered cause be sustained, and that she have up to and including March 18, 2015 in which to complete and file her petition for discretionary review. Petitioner prays for such other and further relief, both general and special, at law or equity, to which she may show herself to be justly entitled.

Respectfully submitted,

By: /s/Michael W. Minton

MICHAEL W. MINTON

State Bar No. 14194550

THE LAW OFFICES OF

MICHAEL W. MINTON, P.L.L.C.

6100 Western Place, Suite W0541 Fort Worth, Texas 76107

mminton@mintonlaw.com

Telephone: 817-377-9200

Facsimile: 817-377-9201

CERTIFICATE OF SERVICE

I hereby certify that on March 18, 2015, a true and correct copy of the

above and foregoing document was sent U.S. certified mail, return receipt requested and/or facsimile transmittal to all counsel of record in the above- styled and numbered cause.

/s/Michael W. Minton

MICHAEL W. MINTON