Webb, Stephen Clark

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