COURT OF CRIMINAL APPEALS

PD-_______-15

State of Texas, Appellant, 

v.

Marcus Lee Holmquist, Appellee.

On Discretionary Review from 

No. 05-13-01388-CR 

Fifth Court of Appeals, Dallas

On Appeal from No. CR13-0496

204th District Court, Dallas County

 

Motion to Extend Time to File 

Petition for Discretionary Review

PATRICK SHORT

State Bar Card No. 21216900

LAW FIRM OF PATRICK SHORT

603 White Hills Drive

Rockwall, Texas 75087

Telephone: (972) 771-1441

Facsimile: (972) 771-0377

patrick@patrickshort.com

Attorney for Appellee 

PD-0401-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 4/8/2015 10:31:44 PM

Accepted 4/15/2015 12:59:34 PM

ABEL ACOSTA

CLERK
Page 2 of 4

To the Honorable Judges of the Court of Criminal Appeals:

Appellee Marcus Lee Holmquist moves for an extension of time of 30 days

to file a petition for discretionary review:

1. On February 5, 2015, in State v. Holmquist, 05-13-01388-CR, the 

County Court at Law in Rockwall County denied the appellee’s motion to suppress 

evidence. 

2. The petition for discretionary review is due on April 9, 2015.

3. For good cause, Appellant asks for an extension of 30 days to file the 

petition for discretionary review, i.e., until May 9, 2015. 

4. No previous extension to file the petition for discretionary review has 

been filed.

5. Appellant relies on the following facts as good cause for the requested 

extension: undersigned attorney Patrick Short just completed a two day criminal 

jury trial involving a Driving While Intoxicated case in Cause Number CR14-0210 

before the County Court at Law in Rockwall County in the State of Texas v. 

Michelle Hill. 

6. Further, Patrick Short has the following briefs or other pleadings due 

soon:

• Response to a traditional and no-evidence motion for summary 

judgment in Oliver v. Lilley, 048-267871-13, 48th Judicial District in 

Tarrant County, due April 26, 2015. 
Page 3 of 4

• Response to a motion to strike the testimony of an expert in Oliver v. 

Lilley, 048-267871-13, 48th Judicial District in Tarrant County, due 

April 26, 2015. 

• Plaintiff’s traditional motion for summary judgment in Oliver v. 

Lilley, 048-267871-13, 48th Judicial District in Tarrant County.

• Preparation for a jury trial that is to being April 14, 2015 styled the 

State of Texas v. Ryan Houston Hughes, CR14-0025, in the Rockwall 

County Court at Law. 

7. This Motion is not filed for purposes of delay, but so that justice may 

be served. 

Prayer

Appellant prays that this Court grant this motion for an extension of time to 

file a petition for discretionary review.

Respectfully submitted,

/S/ Patrick Short

PATRICK SHORT

State Bar Card No. 21216900

LAW FIRM OF PATRICK SHORT

603 White Hills Drive

Rockwall, Texas 75087

Telephone: (972) 771-1441

Facsimile: (972) 771-0377

patrick@patrickshort.com

ATTORNEY FOR APPELLEE
Page 4 of 4

Certificate of Service

I certify that on April 8, 2015, a true and correct copy of this document was 

served. See Tex. Rule App. Proc. 9.5 (2014) and 68.11 (2014).

Kenda Culpepper

Criminal District Attorney

Rockwall County Government Center

1111 E. Yellow Jacket Ln.

Suite 201

Rockwall, TX 75087

Ph: (972) 204-6800

Fx: (972) 204-6809

Jeff Shell

Chief Appellate Section

Rockwall County Government Center

1111 E. Yellow Jacket Ln.

Suite 201

Rockwall, TX 75087

Ph: (972) 204-6800

Fx: (972) 204-6809