Mozee, Stanley Orson

Opinion

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 RECEIVED COURT OF CRIMINAL APPEALS 11/24/2015 EX PARTE § ABEL ACOSTA, CLERK § § 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.

Applicants’ Motion for Extension of Time to File Objections to Trial Court’s Supplemental Findings of Fact on Remand - Page 1 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 GARY A. UDASHEN Bar Card No. 20369590 SORRELS, UDASHEN & ANTON 2311 Cedar Springs Road Suite 250 Dallas, Texas 75201 214-468-8100 214-468-8104 fax Appearing on Behalf of the Innocence Project of Texas

Counsel for Dennis Lee Allen

Applicants’ Motion for Extension of Time to File Objections to Trial Court’s Supplemental Findings of Fact on Remand - Page 2 /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. Bar Card No. 24034715 THE TYSON LAW FIRM 342 W. Montana Avenue Dallas, Texas 75224 214-942-9000 214-942-9001 fax

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 GARY A. UDASHEN

Applicants’ Motion for Extension of Time to File Objections to Trial Court’s Supplemental Findings of Fact on Remand - Page 3