SORRELS l UDASHlEN |ANTON ROBERT N- UDASHEN, P-C
BOARD CERTlFlED-CRIMlNAL LAW and CRlMINAL APPELLATE LAW
TExAs BOARD or Li-:G P Attomeys and Counselors at Law _ AL S ECIALIZ£BN
rnu@sualaw.com
2311 Cedar Springs Rd. Suite 250
Dallas, TX 75201 214.468.8100
fax 214.468.8104 www.sualaw.com
October 2, 2015
l\/ls. Paigc Light
Assistant Court Administrator 54th District Court
501 Washington Avenue Sui_te 305
Waco, Texas 76701
RE: Ex Parte Keith Allen Jones No. 2011-1299-C2A
Dear l\/Is. Light:
l arn enclosing a motion for Judge .lohnson to Sign and forward to the Court of Criminal Appeals asking vt`or an extension of time to resolve the issues in Keith Jones’s writ application l tried to do this myself but could not because the Court of Criminal Appeals wants the extension request to come from the Judge instead of me. lt is necessary to extend the time so that we can have the evidentiary hearing that is set in November.
Thank you for your assistance with this matter.
Yours very truly,
,/ .v"- . `,, ,.
__/
Robert N. Udashen, P.C.
RNU:ps E' 1 .. nc osuic v CO RECE|VED IN CC: Mr. S_terling Harmon URT OF CR|M|NAL APPEALS Assistant District Attorney ` []C]' 12 2015
l dwme@sea.elevi<
exam
A7’ 5 REcEl\/Et) lN 0 'D ' 1 Al: APPEALS al WW»P%/ coan 0_F sam N IN THE CoURT oF CRIMINAL APPEALS UCT 12 2915 FoR THE sTATE oF TExAs AUSTIN, TExAs _ Ab@g AC@SU'C¢§Q Ex PARTE § § § wRIT No. WR-ss, 922-01 ` § KEITH ALLEN JoNEs §
MOTION TO EXTEND TIME FRAME FOR RESOLUTION OF CLAIMS RAISED IN 11.07 APPLICATION
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW THE HONORABLE MATT JOHNSON, Judge presiding, 54th District Court of McLennan County, Texas, and files this Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application and would show this Court the following:
I.
Applicant filed his applications for a writ of habeas corpus on March 23, 2015. The State filed its answer to the applications on April 7, 2015. On April 22, 2015, the district court timely designated the issues for resolution in Applicant’s writ applications Pursuant to Texas Rule Appellate Procedure 73.5, this Court has 180 days from the date the State received the applications to resolve any issues the court timely designated for resolution
II.
The issues designated for resolution by the district court have not yet been
Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application - Page 1
resolved. An evidentiary hearing is scheduled on those issues for November 13, 2015. A hearing could not be scheduled sooner than that date because of various conflicts with the district court’s schedule, the schedules of the parties’ attorneys, and the schedules of Applicant’s trial attorneys, whose testimony is needed at the evidentiary hearing.
III.
The district court respectfully asks that this Court extend the time frame for the district court to resolve the issues in Applicant’s writ applications to a date 45 days after the evidentiary hearing. This will give the district court time to enter findings of fact and conclusions-of law after the hearing
IV. Both parties are unopposed to this motion. FOR THE ABOVE REASONS, the Honorable Matt Johnson, Judge presiding,
respectfully asks that this motion be granted
Respectfully submitted,
The Honbrable Matt J h son Judge presiding
54th District Court of c ennan County, Texas
Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application - Page 2
\
soRREleUDAsHEN ANToN t ' ROBERTN'UDASHEN,P'C~
BOARD CERTIFIED-`CR.IMINAL LAW and CRIMINAL APPELLATE LAW
naxAs BOARD oF 'Attorneys and Counselors at Law » ~‘ LEGAL spEclALlZA-I£N
2311 Cedar Springs R_d. Suite 250
october 2, 42015
‘ Ms. Paige Lighr Assistant Court Administrator 54th District Court k 501 Washington Avenue Sui_te 305 Waco, Texas 76701
Dear Ms. “Light: l am enclosing a'motion for Judge Johnson to sign and forward to the Court of Criminal Appeals asking for an extension of time to resolve the issues in Keith Jones’s writ application l » tried to do this myself but could not because the Court of Criminal-Appeals wants the extension request to come from the Judge instead of me. lt is necessary to extend the time so that we can have the evidentiary hearing that is set in November. '
' Yours very truly,
l Robert N. Udashen, P.C. f RNU:ps Enclosure
' cc: 4 Mr. Sterling Harmon Assistant District Attorney»
IN THE COURT oF CRIMINAL APPEALS F.oR THE sTATE _oF TEXAS " __ AUsTIN, TExAs, Ex PARTE
WRIT NO. WR-83, 922-01
CoJCmCo'->OODCO'J
KEITH ALLEN JoNEs 1 MoTIoN To EXTEND TIME
l FRAME FOR RESOLUTION OF CLAIMS _ RAISED IN 11.07 APPLICATION ’
COMES NOW THE HONORABLE' MATT JOHNSON, Judg'e presiding, 54th District Court of McLennan County, Texas, and files_this Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application and wouldshow this Court the following:
l.
Applicant filed his applications for a writ of habeas corpus on March 23, 2015 . The State filed its answer to the applications on April 7, 2015'. On April 22,2015, the ' b district court timely designated the issues for resolution in Applicant’s writ applications Pursuant to Texas Rule Appellate Procedure 73.5, this Court has 180 days from the date the State received the applications to resolve any issues th'e court timely designated for resolution
ll.
_The issues designated for resolution by the district court have not yet been
Motion.to Extend Time _Frame for Resolution of Claims Raised in 11.07 Application - Page 1
vresolved. An evidentiary hearing is scheduled on those issues for November 13, 2015 . A hearing could not be scheduled sooner than that date because of various conflicts with the district co_urt’s schedule, the schedules of the parties’ attorneys, and the schedules of Applicant’s trial attorneys, whose testimony is needed at-the evidentiary'hearing. lll. The district court respectfully asks that this Court extendthe time frame for the g l . district court to r|esolve the issues in Applicant’s writ applications to a date 45 days after the evidentiary hearing This will give the district court time to enter findings of fact and conclusions -of la;w_ after the hearing IV. Both parties are unopposed to this motion FOR"THE ABOVE REASONS, the Honorable Matt Johnson, Judge presiding,
dltlll<
The _Hon`orable Matt J ‘ son Judge presiding '
Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application - Page 2
soRRE__LSlUDAsHEN|ANToN .1 ~_ ROBERTN UDAS’HEN P c.
BoARD csRnFiED_cRiMiNAL LAW and cRiMiNAL APPF.LLATE LAW 4 rExAs isoAizt) 0 Attom_eys and Counselors at Law . F LEGAL SPECIAUZATION
rnu@sualaw.com 2311 Cedar Springs Rd._ , Suite 250 Dallas, TX 75201', 214.468.8100 fax 214.468.8104 www.sualaw.corn
RECEWED 11\1 COURT CFCR!?.’HNAL APFEALS Ms. Paige Light n
Assistant Cour_t Administrator . . GCT l 2 2915 54th District Court _ _ v ..
501 Washington Avenue ` . _ AB@: ACQS?U§C§@¥!< Sui_te 305 v ` '
`Waco, Texas 76701
RE: Ex Parte Keith Allen Jones No. 2011-1299-C2A ._
Dear Ms. Light:
l am enclosing a motion for 'Judge Johnson to sign and forward to the Court of Criminal Appeals asking for an extension of time to resolve the issues in Keith Jones’s writ application l tried to do this myself but could not because the Court of Criminal Appeals wants the extension
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SORRELS l UDASHlEN |ANTON ROBERT N- UDASHEN, P-C
BOARD CERTlFlED-CRIMlNAL LAW and CRlMINAL APPELLATE LAW
TExAs BOARD or Li-:G P Attomeys and Counselors at Law _ AL S ECIALIZ£BN
rnu@sualaw.com
2311 Cedar Springs Rd. Suite 250
Dallas, TX 75201 214.468.8100
fax 214.468.8104 www.sualaw.com
October 2, 2015
l\/ls. Paigc Light
Assistant Court Administrator 54th District Court
501 Washington Avenue Sui_te 305
Waco, Texas 76701
RE: Ex Parte Keith Allen Jones No. 2011-1299-C2A
Dear l\/Is. Light:
l arn enclosing a motion for Judge .lohnson to Sign and forward to the Court of Criminal Appeals asking vt`or an extension of time to resolve the issues in Keith Jones’s writ application l tried to do this myself but could not because the Court of Criminal Appeals wants the extension request to come from the Judge instead of me. lt is necessary to extend the time so that we can have the evidentiary hearing that is set in November.
Thank you for your assistance with this matter.
Yours very truly,
,/ .v"- . `,, ,.
__/
Robert N. Udashen, P.C.
RNU:ps E' 1 .. nc osuic v CO RECE|VED IN CC: Mr. S_terling Harmon URT OF CR|M|NAL APPEALS Assistant District Attorney ` []C]' 12 2015
l dwme@sea.elevi<
exam
A7’ 5 REcEl\/Et) lN 0 'D ' 1 Al: APPEALS al WW»P%/ coan 0_F sam N IN THE CoURT oF CRIMINAL APPEALS UCT 12 2915 FoR THE sTATE oF TExAs AUSTIN, TExAs _ Ab@g AC@SU'C¢§Q Ex PARTE § § § wRIT No. WR-ss, 922-01 ` § KEITH ALLEN JoNEs §
MOTION TO EXTEND TIME FRAME FOR RESOLUTION OF CLAIMS RAISED IN 11.07 APPLICATION
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW THE HONORABLE MATT JOHNSON, Judge presiding, 54th District Court of McLennan County, Texas, and files this Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application and would show this Court the following:
I.
Applicant filed his applications for a writ of habeas corpus on March 23, 2015. The State filed its answer to the applications on April 7, 2015. On April 22, 2015, the district court timely designated the issues for resolution in Applicant’s writ applications Pursuant to Texas Rule Appellate Procedure 73.5, this Court has 180 days from the date the State received the applications to resolve any issues the court timely designated for resolution
II.
The issues designated for resolution by the district court have not yet been
Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application - Page 1
resolved. An evidentiary hearing is scheduled on those issues for November 13, 2015. A hearing could not be scheduled sooner than that date because of various conflicts with the district court’s schedule, the schedules of the parties’ attorneys, and the schedules of Applicant’s trial attorneys, whose testimony is needed at the evidentiary hearing.
III.
The district court respectfully asks that this Court extend the time frame for the district court to resolve the issues in Applicant’s writ applications to a date 45 days after the evidentiary hearing. This will give the district court time to enter findings of fact and conclusions-of law after the hearing
IV. Both parties are unopposed to this motion. FOR THE ABOVE REASONS, the Honorable Matt Johnson, Judge presiding,
respectfully asks that this motion be granted
Respectfully submitted,
The Honbrable Matt J h son Judge presiding
54th District Court of c ennan County, Texas
Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application - Page 2
\
soRREleUDAsHEN ANToN t ' ROBERTN'UDASHEN,P'C~
BOARD CERTIFIED-`CR.IMINAL LAW and CRIMINAL APPELLATE LAW
naxAs BOARD oF 'Attorneys and Counselors at Law » ~‘ LEGAL spEclALlZA-I£N
2311 Cedar Springs R_d. Suite 250
october 2, 42015
‘ Ms. Paige Lighr Assistant Court Administrator 54th District Court k 501 Washington Avenue Sui_te 305 Waco, Texas 76701
Dear Ms. “Light: l am enclosing a'motion for Judge Johnson to sign and forward to the Court of Criminal Appeals asking for an extension of time to resolve the issues in Keith Jones’s writ application l » tried to do this myself but could not because the Court of Criminal-Appeals wants the extension request to come from the Judge instead of me. lt is necessary to extend the time so that we can have the evidentiary hearing that is set in November. '
' Yours very truly,
l Robert N. Udashen, P.C. f RNU:ps Enclosure
' cc: 4 Mr. Sterling Harmon Assistant District Attorney»
IN THE COURT oF CRIMINAL APPEALS F.oR THE sTATE _oF TEXAS " __ AUsTIN, TExAs, Ex PARTE
WRIT NO. WR-83, 922-01
CoJCmCo'->OODCO'J
KEITH ALLEN JoNEs 1 MoTIoN To EXTEND TIME
l FRAME FOR RESOLUTION OF CLAIMS _ RAISED IN 11.07 APPLICATION ’
COMES NOW THE HONORABLE' MATT JOHNSON, Judg'e presiding, 54th District Court of McLennan County, Texas, and files_this Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application and wouldshow this Court the following:
l.
Applicant filed his applications for a writ of habeas corpus on March 23, 2015 . The State filed its answer to the applications on April 7, 2015'. On April 22,2015, the ' b district court timely designated the issues for resolution in Applicant’s writ applications Pursuant to Texas Rule Appellate Procedure 73.5, this Court has 180 days from the date the State received the applications to resolve any issues th'e court timely designated for resolution
ll.
_The issues designated for resolution by the district court have not yet been
Motion.to Extend Time _Frame for Resolution of Claims Raised in 11.07 Application - Page 1
vresolved. An evidentiary hearing is scheduled on those issues for November 13, 2015 . A hearing could not be scheduled sooner than that date because of various conflicts with the district co_urt’s schedule, the schedules of the parties’ attorneys, and the schedules of Applicant’s trial attorneys, whose testimony is needed at-the evidentiary'hearing. lll. The district court respectfully asks that this Court extendthe time frame for the g l . district court to r|esolve the issues in Applicant’s writ applications to a date 45 days after the evidentiary hearing This will give the district court time to enter findings of fact and conclusions -of la;w_ after the hearing IV. Both parties are unopposed to this motion FOR"THE ABOVE REASONS, the Honorable Matt Johnson, Judge presiding,
dltlll<
The _Hon`orable Matt J ‘ son Judge presiding '
Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application - Page 2
soRRE__LSlUDAsHEN|ANToN .1 ~_ ROBERTN UDAS’HEN P c.
BoARD csRnFiED_cRiMiNAL LAW and cRiMiNAL APPF.LLATE LAW 4 rExAs isoAizt) 0 Attom_eys and Counselors at Law . F LEGAL SPECIAUZATION
rnu@sualaw.com 2311 Cedar Springs Rd._ , Suite 250 Dallas, TX 75201', 214.468.8100 fax 214.468.8104 www.sualaw.corn
RECEWED 11\1 COURT CFCR!?.’HNAL APFEALS Ms. Paige Light n
Assistant Cour_t Administrator . . GCT l 2 2915 54th District Court _ _ v ..
501 Washington Avenue ` . _ AB@: ACQS?U§C§@¥!< Sui_te 305 v ` '
`Waco, Texas 76701
RE: Ex Parte Keith Allen Jones No. 2011-1299-C2A ._
Dear Ms. Light:
l am enclosing a motion for 'Judge Johnson to sign and forward to the Court of Criminal Appeals asking for an extension of time to resolve the issues in Keith Jones’s writ application l tried to do this myself but could not because the Court of Criminal Appeals wants the extension
’ iequest to come from the Judge instead of me lt is necessary to extend the time so that we can have the evidentiary hearing that is set in November.
Yours very truly, n
iam/net
RobertN. Udashen, P. C. RNU:ps Enclosure
cc: \ Mr. Sterling&H_armon Assistant District Attorney
` - KEITH ALLEN JoNEs
IN THE COURT oF CRIMINAL A`PPEALS _ FoR THE sTATE oF TEx_AS AUsTIN, TEXAS Ex PARTE
WRIT'NO. WR-83, 922-01
w$cmomooo
MOTION TO`EXTEND TIME FRAME FOR RESOLUT-ION OF CLA]JV[S RAISED IN~11.`07 APPLICATIO_N TO }TH_E HO`NORABLE COURT OF CRIMINAL APPEALS:
COMES NO`W THE HONORABLE MAT_T JOHN_SON,'Judge 'presiding, 54th District Court of l\/chennan~ County, Texas, and files't'his_Motion to Extend Time Frame for Resolution of Claims'Raised in 11.07'App1ication and would show this Court the _following: il `
Applicant filed*his applications for a writ of habeas corpus on March 23, 2015. ' The State filed its answer to the applications on April 7,'-2015. On `_April '22, 2015, the district court timely designated the issues for resolution in|Applicant’swrit applications Pursuant to Texas Rule Appellate Procedure 73.5, this Court has 180 days from the date the State received the applications to resolve any issues the court timely designated for v resolution_.' v
The issues designated for resolution by the district court have not yet been
Motion to Extend Time Frame for Resolution of Claims Raised in 11.07 Application - Page 1
resolved An evidentiary hearing is scheduled on those issues for Novemberl 13,, 2015. A ~ hearing could not be scheduled sooner than that date because of various conflicts with the district court’s sche`dule, the schedules _of the parties’ attorneys, and the schedules of Applicant’s trial attorneys, .whose testimony is needed at the evidentiary hearing.` ` III.
. The-district court respectfully asks'that this Court extend the.time frame for the district court to resolve the issues in Applicant’s writ applications to a date 45 days after the evidentiary hearing This will give the district court time to enter findings of fact and
conclusions -of law after the hearing d 1 IV.
Both parties are unopposed to this motion
FOR,THE AB'OVE REASONS, the Honorable -Mat't Johnson, Judge presiding,
111@111<
The Honi)rable Matt J§' hinson
Judge presiding 54th District Court of c ennan County, Texas
'_ Motion~ to Extend Time Frame for Resolution of Claims Raised in 11.07 Applicatio_n - Page 2