CERTIFICATE OF SERVICE

[hereby certify that a copy of the above and foregoing Petitioner’s Motion To
Extend Time to File Petition for Discretionary Review was faxed to the State of

Texas via the Hays County District Attorney's Office, on April 14, 2015.

Be FRO

Stephen Foster



WHEREFORE, PREMISES CONSIDERED, Petitioner prays that this Court
grant this Motion To Extend Time to File Petition for Discretionary Review, and for such

other and further relief as the Court may deem appropriate.

Respectfully submitted,
O78 2D oe

Stephen Foster

310 South Saint Mary’s Street,

24" Floor, Tower Life Building

San Antonio, Texas 78205

(210) 222-1200

(210) 222-1253 (Facsimile)

SBN: 24005529



ORDER ON PETITIONER’S MOTION FOR EXTENSION OF
TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

On this day the day of , 2015, Appellant's

Motion to Extend Time to File Appellant's Brief was

GRANTED

__ DENIED

Extension of time was granted to , 2015.

JUDGE PRESIDING


PD-04160-15

IN THE COURT OF CRIMINAL APPEALS

FOR THE STATE OF TEXAS

ced

THIRD DISTRICT OF TEXAS COURT OF APPEALS CAUSE NO. 03-12-00787-CR

took

MARK VERNON MOORE
Appellant
VS.
THE STATE OF TEXAS

Appellee

RR

RELATING TO DENIED APPEAL FROM THE THIRD DISTRICT COURT OF APPEALS ON
CASE FROM THE 274TM JUDICIAL DISTRICT COURT IN HAYS COUNTY, TEXAS

oad

MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

FILED IN
COURT OF CRIMINAL APPEALS

April 15, 2015 Stephen Foster

310 South Saint Mary’s Street
24" Floor, Tower Life Building
San Antonio, Texas

SBN: 24005529

ATTORNEY FOR PETITIONER,
MARK VERNON MOORE

ABEL ACOSTA, CLERK


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

Now comes MARK VERNON MOORE, PETITIONER in the above styled and
numbered cause, and moves this Court to grant an extension of time to file Petitioner’s
Request for Discretionary Review pursuant to Rule 10.5 of the Texas Rules of Appellate

Procedure, and for good cause shows the following:

The conviction on the charge of Continuous Sexual Abuse of a Child that is the subject
of this motion was Affirmed by the Texas Court of Appeals, Third District in Austin in case

No. 03-12-00787-CR on March 20, 2015.

The Deadline for filing a Petition for Discretionary Review is Sunday, April 19, 2015.

Therefore, the Petition for Discretionary Review must be filed by Monday, April 20, 2015.

Il.

The case at the trial Court was styled the STATE OF TEXAS v. MARK VERNON MOORE

and numbered CR-11-0929 and was tried in the 274* Judicial District Court of Hays County,

Texas.

IV.


This is Petitioner’s first Motion to Extend Time to File Petition for Discretionary

Review.

There have been no motions for reconsideration or requests for En Banc review in

this case.

VI.

Stephen Foster, Counsel for Petitioner has not yet received payment or a copy of the
signed employment agreement in this case. He has, however, been assured that it is all being
sent through the United States Postal Service. The opinion in this case from the Third
District Court of Appeals, Austin is 37 pages long and addresses 12 separate points of error
that the Petitioner presented to the Intermediate Appellate Court, which were all rejected for

a variety of reasons.

VII.

Stephen Foster, Counsel for Petitioner requests an extension of an additional 30 days
in order to fully and clearly prepare a Petition for Discretionary review. This would make the
Petition for Discretionary Review due on Tuesday, May 19, 2015. Alternatively, Counsel for
Petitioner requests an extension of a lesser amount of time that the Texas Court of Criminal

Appeals determines to be appropriate.