Volume I ofI SUPPLEMENTAL TRANSCRIPT Trial Court No. D-l-DC-ll-300144-B In the 390TH Judicial District Court ofTravis County, Texas, Honorable JULIE KOCUREK, Judge Presiding.
Ex Parte: KEITH TAYLOR, Applicant 

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APPLICATION FOR POST CONVICTION WRIT OF HABEAS CORPUS transmitted to the Court ofCriminal Appeals for the State ofTexas, at Austin, Texas. 

### RECEIVED IN COURT OF CRIMINAL APPEALS Attorney for Applicant 

### prose JUN 25 2015 

## Attorney for State: AMASQSta, Clerk MR. ROSEMARY LEHMBERG, District Attorney Travis County, Texas P.O. Box 1748 Austin, Texas 78767 

## )1^^H|RED td thejGoujt ofCrMkfe^peals for the State ofTexas, at Austin, Texas, on the
VELVA L. PRICE 

### District Clerk, Travis CounM^ip

JESSICA CONTRERAS, Deputy
Court ofCriminal Appeals No. FILED in the Court ofCriminal Appeals for the State ofTexas, at Austin, Texas, this day of , . ABEL ACOSTA, Clerk By: , DeputyIndex

CAPTION 1 TRIAL COURT'S REQUEST FOR EXTENSION OF TIME TO PREPARE FINDING OF FACTS AND CONCLUSIONS OF LAW AND TO FORWARD SAID FINDINGS AND CONCLUSIONS ALONG WITH SUPPLEMENTAL RECORD 2 CLERK'S RECORD CERTIFICATE 6THE STATE OF TEXAS COUNTY OF TRAVIS CAPTION

In the 390TH JUDICIAL DISTRICT COURT ofTravis County, Texas, the 

### Honorable JULIE KOCUREK, Judge Presiding, the following proceedings were held 

### and the following instruments and other papers were filed in this cause, to-wit: Trial Court Cause Number: D-1-DC-11-300144-B THE STATE OF TEXAS IN THE 390TH JUDICIAL DISTRICT COURT VS. OF KEITH TAYLOR TRAVIS COUNTY, TEXAS

APPLICATION FOR POST CONVICTIN WRIT OF HABEAS CORPUS



### 000001EX PARTE

KEITH TAYLOR 

### NO. WR-79,497-05 & 79,497-06
IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS § § § IN THE DISTRICT COURT OF TRAVIS COUNTY, TEXAS 390TM DISTRICT COURT D1DC 11-300144 &D1 DC 12-904028-B TRIAL COURT'S REQUEST FOR EXTENSION OF TIME TO PREPARE FINDING OF FACTS AND CONCLUSIONS OF LAWAND TO FORWARD SAID

FINDINGS AND CONCLUSIONS ALONG WITH SUPPLEMENTAL RECORD
TO THE HONORABLE COURT OF CRIMINAL APPEALS: 

### The 390thJudicial DistrictCourt of Travis Countyrespectfullymoves for an extension of time to complywith this Court's orderto preparefindings offactand conclusions oflaw regardingthe claimsraised in Applicant's writ applicationand, in accordancewith Tex. R. App. Proc. 10.5(b), the trial court submits the following: (a) Applicant pled to the offense ofaggravated robbery and solicitationto commit capital murder on April 27,2012. 

### (b) On December 4,2014, the Applicant filed an Application for a Writ ofHabeas 

### Corpus. He subsequently amended his Application on March 30,2015. (c) This Court issued an order on March 25,2015 remanding the instant matterto

1
Velva L.Trlce, District Clerk Filed In j

of Tra\ on 

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000002

### the trial court in order to allow the trial court to prepare findings offact and conclusions oflaw regarding the claims raised in Applicant's writ application. (d) The order issued by this Court directed the trial court to resolve the fact issues related to the Applicant's claim by June 23,2015. This Court further ordered 

### the trial court to forward, to this Court, a supplementaltranscriptcontainingall affidavits and interrogatories or the transcription ofthe court reporter's notes 

### from any hearing or disposition, along with the trial court's supplemental findings offact and conclusions oflaw by July 23,2013. 

### (e) This request is for an extension of 60 days to prepare findings of fact and conclusions oflaw regarding the claims raised in Applicant's writ application and to forward, to this Court, a supplementaltranscript containing all affidavits and interrogatories or the transcription ofthe court reporter's notes from any hearing or disposition, along with the trial court's supplemental finds offact and conclusions of law. 

### (f) The number ofprevious extensions oftime granted to prepare findings offact and conclusions of law regarding the claims raised in Applicant's writ application is: none. (g) The trial court relies upon the following facts to reasonably explain the need for an extension oftime: 1. The merits ofthis Application are still under investigation. 

### 2. Given the age ofthis matter, attempts remain ongoing to find and interview



### 000003

### witnesses withinformation relevanttotheapplication withparticularemphasis
on addressing Applicant's claim ofineffective assistance ofcounsel for trial 

### counsel's failure to investigate whether Applicant could have relied on the 

### promiscuity defense available underTexasPenalCode22.011 (d)(1)atthetime the offense was committed. 

### 3. This request is not made for the purpose of delay, but to ensure that the 

### Court has a proper response to aid in thejust dispositionofthe above cause. 

### WHEREFORE, PREMISES CONSIDERED, the trialcourtrespectfully requests an extension oftime to the Honorable Clifford Brown to the trial court to resolve the fact issues 

### related to the Applicant's claimuntil August 22,2015. The trial court further requests an extension oftimeto forward, to this Court, a supplemental transcript containing allaffidavits and interrogatories or the transcription of the court reporter's notes from any hearing or disposition,along with the trial court's supplemental findings offact and conclusions oflaw until September 21,2015. Respectfully submitted, 

## j^Judge Julie Kocui rek, 390th District Court Travis County, Texas



### 000004CERTIFICATE OF SERVICE 

### This is to certifythat a true and correctcopyof this motion is beingservedby U.S. 

### mail, electronic mail, facsimile or by hand-delivery, to Travis County Assistant District Attorney Kathryn Scales and to the Applicant at: Keith Taylor M.S.U. 

### Rusk State Hospital P.O.Box318 Rusk, TX 75785 

### M 

# i^SL LKJJT* jdge Julie Kocurek, 

## feo* District Court Travis County, Texas



### 000005CLERK'S RECORD CERTIFICATE

THE STATE OF TEXAS COUNTY OF TRAVIS 

### I, VELVA L. PRICE, Clerk ofthe District Courts ofTravis County,Texas, do 

### hereby certify that the documents contained in this record to which this certifications is attached are all ofthe documents specified by Texas Rule ofAppellate Procedure 34.5 (a) and all other documents timely requested by a party to this proceeding under Texas Rule ofAppellate Procedure 34.5 (b).

GIVEN UNDER MY HANDA 

### Travis County, Texas, this the VELVA L. PRICE 

### District Clerk, Travis County, Texas



### 000006