Jackson, Raul David

Opinion

WR-73,697-06,07,08,09 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 5/19/2015 2:50:52 PM Accepted 5/22/2015 8:26:08 AM ABEL ACOSTA WRIT NOS. W06-00445-K(B), W06-00448-K(B), W06-00450-K(B) and CLERK W06-00453-K(B) RECEIVED COURT OF CRIMINAL APPEALS 5/22/2015 In the ABEL ACOSTA, CLERK Texas Court of Criminal Appeals At Austin

From the CDC No. 4 Dallas County, Texas

EX PARTE RAUL DAVID JACKSON, Applicant,

11.07 Writ

MOTION FOR EXTENSION OF TIME TO TURN IN FINDING OF FACTS AND CONLUSIONS OF LAW

Bruce Kaye TBN. 00784374 2309 Boll St. Dallas, TX 75204 (214) 722-7438 Appointed Writ Master, CDC 4

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: 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 due on or about May 20,

2015.

II.

This 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 Writ Master has been involved in numerous Appellate matters for

both state and federal cases. One case was a Capital Murder (non death penalty) which

produced a 100 page brief. Currently, there are three (3) appeals all due within the next 30

days and two (2) trials also scheduled in the same time frame. An additional 90 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 Fact and Conclusions of Law for

the Court. WHEREFORE, PREMISES CONSIDERED, the undersigned Writ Master prays

this Court grant his Motion for Extension of Time to Turn in Finding of Facts and

Conclusions of Law.

Respectfully submitted,

/s/ Bruce Kaye BRUCE C. KAYE

By: Bruce Kaye TBN 00784374 Appointed Writ Master

2309 Boll. St. Dallas, TX 75204 (214) 722-7438 (866) 649-8757 facsimile Bruce@brucekaye.com CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of this document was tendered to Dallas County District Clerk’s Office, on the 20th Day of May, 2015, in accordance with the Texas Rules of Appellate Procedure.

/s/ Bruce Kaye BRUCE C. KAYE ,