CASE NO. PD-0599-15

IN THE TEXAS COURT OF CRIMINAL APPEALS

_______________________________________________________________

THE STATE OF TEXAS

Appellant

v.

MARK TWAIN SIMPSON

Appellee

________________________________________________________________

FROM THE FIFTH COURT OF APPEALS

CAUSE NO.05-14-00618-CR

ON APPEAL FROM CRIMINAL DISTRICT COURT NO. 4

DALLAS COUNTY, TEXAS

 TRIAL COURT NO. F-1356596-K

THE HONORABLE DOMINIQUE COLLINS PRESIDING

APPELLEE’S MOTION FOR EXTENSION OF TIME TO 

FILE BRIEF ON PETITION FOR DISCRETIONARY REVIEW

BRUCE ANTON

State Bar No. 01274700

ba@sualaw.com

SORRELS, UDASHEN & ANTON

2311 Cedar Springs, Suite 250

Dallas, Texas 75201

(214) 468-8100 (office)

(214) 468-8104 (fax)

Attorney for the Appellee 

1

PD-0599-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 10/26/2015 10:38:40 AM

Accepted 10/26/2015 10:56:03 AM

ABEL ACOSTA

CLERK
COMES NOW, MARK TWAIN SIMPSON, Appellee herein, and moves

this court to issue an extension of time to file his brief on petition for discretionary

review, and in support thereof would show the court as follows:

I.

Appellee’s brief is currently due on October 23, 2015. Attorney for the

Appellee requests an additional 30 days, until November 22, 2015, top file the

brief.

II.

The number and style of the case in the District Court is No. F-1356596-K,

State of Texas v. Mark Twain Simpson. 

 III.

Appellant was convicted of robbery 2nd. The Appellee plead guilty as terms

of a plea bargain and was sentenced before the judge to twenty five years’

imprisonment.

IV.

No extensions of time to file the brief were previously requested.

V.

The reason for this request is that during the last few weeks counsel has been

working on the following:

1. Petition for Writ of Certiorari in Charles Don Flores v. William

Stephens, Director, in the Supreme Court of the United States.

APPELLEE'S MOTION FOR EXTENSION OF TIME- PAGE 2
2. Petition for Discretionary Review in Cristal Paullett Richardson v.

The State of Texas, case no. PD-1172-15 in the Texas Court of

Criminal Appeals. 

3. Appellant’s Reply Brief in Vincent Dewayne Johnson v. The State of

Texas, cause nos. 05-15-00403-CR, 05-15-00404-CR and 05-15-

00405-CR in the Fifth Court of Appeals of Texas.

4. Application for Writ of Habeas Corpus and Memorandum in Support

in Ex Parte Eduardo Enrique Alfaro, in the 401st Judicial District

Court of Collin County, Texas. 

VI.

For the reasons set out above, counsel for Mark Twain Simpson will, in

reasonable likelihood, be unable to submit the brief on petition for discretionary

review requested by this court by October 23, 2015. Counsel is asking for an

extension of time of 30 days to file the brief.

WHEREFORE, PREMISES CONSIDERED, Appellant requests this court

to grant an extension of time to file his brief until November 22, 2015.

RESPECTFULLY SUBMITTED,

 /s/ BruceAnton 

BRUCE ANTON

Texas State Bar No. 01274700

SORRELS, UDASHEN & ANTON

2311 Cedar Springs #250

Dallas, Texas 75201

(214) 468-8100

(214) 468-8104 (fax)

ATTORNEY FOR APPELLEE

APPELLEE'S MOTION FOR EXTENSION OF TIME- PAGE 3
CERTIFICATE OF SERVICE

I do hereby certify that a true and correct copy of the above entitled motion

for extension of time was electronically served to the Appellate Division of the

Dallas County District Attorney’s Office and to the State Prosecuting Attorney on

this 22nd day of October, 2015.

/s/ Bruce Anton 

BRUCE ANTON

 

APPELLEE'S MOTION FOR EXTENSION OF TIME- PAGE 4