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



### B RUCE 

### A NTON State Bar No. 01274700 ba@sualaw.com S ORRELS , U DASHEN & A NTON 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 CLERKCOMES NOW, MARK TWAIN SIMPSON, Appellee herein, and moves this court to issue an extension of time to file his brief on p etition for discretionary review, and in support thereof woul d 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, 201 5, 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 2 nd . 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 request ed. V. The reason for this request is th at during the last few weeks c ounsel 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 22. 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 Suppo rt in Ex Parte Eduardo Enrique Alfaro, in the 401 st Judicial District Court of Collin County, Texas. VI. For the reasons set out above, counsel for Mark Twain Simpson w ill, in reasonable likelihood, be unable to submit the brief on petitio n for discretionary review requested by this cour t by October 23, 2015. Counsel is asking for an extension of time of 30 days to file the brief. WHEREFORE, PREMISES CONSIDERE D, Appellant requests this court to grant an extension of time to file his brief until November 22, 2015. RESPECTFULLY SUBMITTED, /s/ BruceAnton 

### B RUCE 

### A NTON Texas State Bar No. 01274700 S ORRELS , U DASHEN & A NTON 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 3CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the above e ntitled motion for extension of time was electronically served to the Appellat e Division of the Dallas County District Attorney’s Office and to the State Pros ecuting Attorney on this 22 nd day of October, 2015.
/s/ Bruce Anton BRUCE ANTON

APPELLEE'S MOTION FOR EXTENSION OF TIME- PAGE 4