Senn, William Bruce Jr.

Opinion

PD-1420&1421&1422-15 COURT PD-1420&1421&1422-15

OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 11/4/2015 12:46:09 PM Accepted 11/5/2015 2:46:45 PM No. _____________________ ABEL ACOSTA CLERK

WILLIAM BRUCE SENN, JR., § IN THE APPELLANT § §

V. § TEXAS COURT OF §

THE STATE OF TEXAS, § APPELLEE § CRIMINAL APPEALS

APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF THE TEXAS COURT OF CRIMINAL APPEALS:

COMES NOW, William Bruce Senn, Jr, Appellant in the above-styled and numbered cause, by and through his court appointed attorney of record, Jack V. Strickland and files this motion for extension of time to file petition for discretionary review. In support of said motion, Appellant shows as follows:

1.

That Appellant took his appeal from the 43rd Judicial District Court of Parker County, Texas, to the Second Court of Appeals sitting in Fort Worth, Texas. In his appeal, Appellant raised a a single point of error arising from the three felony convictions which formed the basis of that appeal.

2.

On October 1, 2015, in an unpublished opinion, the Court of Appeals affirmed the judgments of the trial court. Appellant did not request a rehearing.

November 5, 2015

3.

That Appellant’s petition for discretionary review is accordingly due on Monday, November 2, 2015, the first business day following the expiration of 30 days after the day the court of appeals’ judgment was rendered. R. 68. 2 (a), TEX. R. APP. PROC.

4.

That Appellant now timely requests an extension of time in which to file his petition.

Appellant requests that this court order the filing of his petition not later than Wednesday, November 25, 2015, an extension of 23 days. R. 68. 2 (C), TEX. R. APP. PROC.

5.

That Appellant’s counsel is involved in a significant number of criminal cases in both State and Federal court, including appeals and trial matters that include significant felony allegations.

6.

That this is Appellant’s first motion for extension of time for the filing of a petition for discretionary review.

7.

That Appellant is incarcerated.

8.

That this motion is not merely for purposes of delay, but in order that justice may be done.

WHEREFORE, PREMISES CONSIDERED, Appellants prays that the Court grant this motion and order that Appellant’s petition for discretionary review be filed not later than November 25, 2015.

Respectfully Submitted,

Jack V. Strickland

_______________________________

JACK V. STRICKLAND

ATTORNEY FOR DEFENDANT

112 Hogle Street

Weatherford, Texas 76086

817.594.2161 (phone)

817.594.2160 (fax)

jvstrickland1943@gmail.com State Bar No. 19397000

Certificate of Conference On October 30, 2015, a telephone conference was held with Parker County Assistant District Attorney Edward Lewallen concurring the foregoing motion. Mr. Lewallen has no objected to the granting of the motion.

Jack V. Strickland

______________________________

Jack V. Strickland

Certificate of Service

On October 30, 2015, a true and correct copy of the foregoing motion was emailed to Mr.

Lewallen at edward.lewallen@outlook.com.

Jack V. Strickland

______________________________

Jack V. Strickland