Jackson, Raul David

Opinion

WR-73,697-06,07,08,09 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/18/2015 10:58:45 PM Accepted 8/19/2015 8:28:42 AM WRIT NO. W06-­‐00445-­‐K(B),

W06-­‐00448-­‐K(B), W06-­‐00450-­‐K(B) and ABEL ACOSTA CLERK

W06-­‐00453-­‐K(B)

RECEIVED

COURT OF CRIMINAL APPEALS WR-­‐73, 697-­‐06, 07, 08, 09 8/19/2015

ABEL ACOSTA, CLERK

In the Texas Court of Criminal Appeals

At Austin

From the CDC No. 4

Dallas County, Texas

EX PARTE RAUL DAVID JACKSON

11.07 Writ

MOTION FOR EXTENSION OF TIME TO FILE FINDING OF FACTS AND

CONCLUSIONS OF LAW

Bruce C. Kaye

2309 Boll St.

Dallas, TX 75204

(214) 722-­‐7438

APPOINTED WRIT MASTER, CDC 4

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 now

due on August 19, 2015, per this Court’s Order dated on or about May 19, 2015.

II.

The 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 appointed Writ Master has been involved in numerous

Appellate and trial matters in both state and federal court.

Currently, Counsel is

long medicare fraud case involving over 1200 pages of transcripts.

Counsel is also

completing an appointed sentencing memorandum in a federal case involving the

fraudulent filing of 30 million dollars of tax claims with the IRS (with extensive

discovery to review).

Counsel is also set for an appointed murder trial in state

court for the first week of October and also set for a federal trial in October

involving 4 terabytes of discovery (medical clinic allegedly prescribing hydrocodone

for everyone who asks).

IV.

An additional 120 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 Facts and Conclusions of Law for the Court.

WHEREFORE, PREMISES CONSIDERED, the appointed Writ Master for CDC

4, Dallas County, Texas, prays this Court grant his Motion for Extension of Time to

File Finding of Facts and Conclusions of Law and set a new due date for 120 days

from the current due date of August 19, 2015.

Respectfully submitted,

/s/ Bruce C. Kaye

TBN. 00784374

Dallas, Texas 75204

(214) 722-­‐7438 office

(866) 649-­‐8757 fax

bruce@brucekaye.com