Webb, Stephen Clark

• Court: Court of Appeals of Texas
• Decided: October 15, 2015
• Docket: PD-1340-15
• Status: Published

Opinion

PD-1340-15 PD-1340-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 10/12/2015 10:57:15 PM Accepted 10/15/2015 1:55:15 PM ABEL ACOSTA COURT OF CRIMINAL APPEALS NO. __________________ CLERK

ON APPEAL FROM COURT OF APPEALS NO. 01-14-00174-CR

TRIAL COURT CAUSE NO. 1389676

STEPHEN CLARK WEBB § IN THE TEXAS COURT OF § vs § § THE STATE OF TEXAS § CRIMINAL APPEALS

APPELLANT’S MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

COMES NOW, STEPHEN CLARK WEBB, Appellant in the above-entitled

and numbered cause, and files this, Appellant’s Motion to Extend Time to File

Petition for Discretionary Review, and for good cause moves the Court to grant an

extension as follows:

1. Appellant intends to file a Petition for Discretionary Review asking the

Court to grant the petition on the grounds that the Court of appeals

either decided an important question of state law that has not been, but

should be, settled by the Court of Criminal Appeals and which conflicts

with applicable decisions of the Court of Criminal Appeals.

2. The deadline for filing a Petition for Discretionary Review in this matter

is October 12, 2015.

October 15, 2015 3. Appellant is seeking a 30 day extension to file his Petition for

Discretionary Review.

4. Appellant seeks additional time to file his Petition for Discretionary

Review for the following reasons:

a) Appellant counsel is the midst of reviewing the record and

responding to an appeal in a three week jury trial on a custody

case currently pending in the 14th Court of Appeals;

b) Appellant’s counsel recently completed a week long trial

modification trial in the District Court of Harris County.

c) Appellant has been preparing responses to two motions for

summary judgment involving complex financial matters in a case

currently pending in Harris County, Texas

5. There has been no previous extension granted regarding the filing of a

Petition for Discretionary Review and the Harris County District

Attorney’s Office does not oppose the extension requested.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court

grant this Motion and extend the time to file his Petition for Discretionary Review

until November 12, 2015. Respectfully submitted,

/s/ John S. Cossum JOHN S. COSSUM TSB #04854500 440 Louisiana, Suite 900 Houston, TX 77002 Telephone: (713) 222-6134 Facsimile: (713) 222-6144 E-Mail: jcossum@cossumlaw.com

ATTORNEY FOR APPELLANT, STEPHEN CLARK WEBB

CERTIFICATE OF SERVICE

As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d) and (e),

I certify that a true and correct copy of the foregoing document has been delivered to

the party listed below via electronic transmission on this 12th day of October, 2015.

Eric Kugler Assistant District Attorney on Appeal TBC # 796910 Harris County District Attorney’s Office 1201 Franklin, Suite 600 Houston, Texas 77002 Telephone: (713) 755-5826

ATTORNEY FOR APPELLEE, STATE OF TEXAS

/s/ John S. Cossum JOHN S. COSSUM