1 Cause No. PD
- 1396
- 14 COURT OF CRIMINAL APPEALS OF TEXAS
JON THOMAS FORD , § Petitioner, § § FROM THE
vs. § FOURTH COURT OF APPEALS § SAN ANTONIO, TEXAS THE STATE OF TEXAS , § 04
- 12
- 00317
- CR Respondent. §
UNOPPOSED MO TION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS:
NOW COMES Pe t itioner , JON THOMAS FORD, by and through his undersigned counsel, and files this Unopposed Motion for Extension of Time to file his Brief, pursuant to Rule 38.6(d) of the Texas Rules of Appellate Procedure. Appellant r espectfully requests a forty (4 0) day extension to and including April 15, 2015

. This is Petitioner’s first motion for extension of time to file his brief. In support of this m otion Petitioner would show as follows:
1. Petitioner’s brief is currently due on March 6, 2015

. 2. Counsel has conferred with Jay Brandon , Bexar County Assistant District Attorney, and he do se not oppose this motion. PD1396-14 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 2/26/2015 4:35:09 PM Accepted 2/26/2015 4:37:10 PM

ABEL ACOSTA CLERK2 Undersigned Counsel has the following judi cial conflicts:
3. Undersigned counsel was in Court for a Motions hearing on February 4,
2015 and February 6, 2015 in United States of America v. Wissam Allouche , Cause No. 13

- CR

- 00420 in the United States District Court fo r the Western District of Texas , whe n the Order granting Petitioner’s Discretio nary Review and Notice of Brief deadline was filed in this case.
4. Undersigned counsel then started Trial on February 9, 2015 in United States of America v. Wissam Allouche , Cause No. 13

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- 00420 in the United
State s District Court for the Western District of Texas . The Trial concluded on February 20, 2015

. 5. Undersigned counsel had out of town meetings scheduled on February 23,
2015 in regard to State of Texas v. Joseph Fredrick Karr , Cause No. D

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- DC

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- 302194 in the 147 th District Court of Travis County, Texas . Wherei n she represents a victim in a c apital murder case.
6. Undersigned counsel has a Plea deadline on March 9, 2015 in United States of America vs. Kunlin Hsieh , Cause No. 14

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- 00641 in the United States Dist rict Court for the Western District of Texas. An ITAR and EAR case.
7. Undersigned counsel is set for Docket C all and Rearraignment on March 12,
2015 in United States of America vs. Kunlin Hsieh , Cause No. 14

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- 00641 in the United States District Court for t he Western District of Texas.3 8. Undersigned Counsel is preparing a Motion for New Trial and Motion for Judgment not Withstanding the Verdict in United States of America v. Wissam Allouche , Cause No. 13

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- 00420 in the United States District Court for the Wes tern District of Texas, that is due on March 13, 2015

. One Count was acquitted and the government’s theory on Count T hree varied fatally from the indictment as well as the Court declined to provide a proper and requested jury instruction to the jury on Cou nt Two and a proper and requested note answer on Count Three.
9. Undersigned counsel is set for Jury Selection and Trial on March 16, 2015 in United States of America vs. Kunlin Hsieh , Cause No. 14

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- 00641 in the United States District Court for the Western District of T exas. 10. Undersigned counsel is preparing Findings of Fact and Conclusions of Law in a Writ of Habeas Corpus proceeding in Ex Parte James R. Hiatt , Cause
No. 2006

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- 2741

- W3 in the 144 th Judicial District Court, Bexar County, San Antonio, Texas.
11. Undersigned counsel is set for Jury Selection and Trial on March 23, 2015
in United States of America v. Oguzhan Aydin , Cause No. 12

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- 00221 in the United States District Court for the Northern District of Georgia.4 12. Undersigned counsel is preparing for and is set for a Motions he aring on March 31, 2015 in Ex Parte James Moore , Cause No 00

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- K26 in the 26 th Judicial District Court, Williamson County, Texas.
13. Undersigned counsel is investigating discovery and preparing replies to responses to pretrial motions in United States of A merica v. Curtis DeBerry , Cause No. 14

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- 00524 in the United States District Court for the Western District of Texas. The Plea Deadline is on April 3, 2015 and a Motions Hearing is set on April 8, 2015. Undersigned counsel has the following professional conflicts:
14. Undersigned counsel is Chair of the American Bar Association’s Criminal Justice Section. She is obligated and has pre

- arranged plans to speak at the Section’s National Summit on Collateral Consequences on February 27, 2015 in Washington, D.C. and also at the 29 th Annual National Institute on White Collar Crime Seminar on March 4

- 6, 2015 in New Orleans, Louisiana.
15. Undersigned counsel also has pre

- arranged plans and obligations to teach at the National Association of Criminal Defense Lawyers Wh ite Collar Crime Defense College on March 12

- 15, 2015 in St. Pete Beach, Florida.5 16. Undersigned counsel is participating in and has pre

- arranged plans to attend the Hadi Hearing on March 23

- 28, 2015 as an NGO observer in Guantanamo Bay, Cuba.
PRAYER FOR RE LIEF WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays that this Honorabl e Court grant him an additional forty ( 4 0 ) days to and including April 15, 2015 to file his brief and for any other relief under this Court’s supervisory power.
Res pectfully submitted:

CYNTHIA E. ORR Bar No. 15313350 GOLDSTEIN, GOLDSTEIN & HILLEY 310 S. St. Mary’s St. 29 th Floor Tower Life Building San Antonio, Texas 78205 210

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- 1463 210

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- 8367 facsimile By:___ /s/ Cynthia E. Orr

______ CYNTHIA E. ORR Attorney for Petitioner, JON THOMAS FORD6 CERTIFICATE OF SERVICE I hereby certify that a copy of the above foregoing Unopposed Motion for Extension of Time to File Brief has been served via e - mail through the EFSP Electronic Filing System , to Jay Brandon , Assist ant Criminal District Attorney , jay.brandon@bexar.org , on this the 2 6 th day of February , 20 15

. By: _/s/Cynthia E. Orr________ CYNTHIA E. ORR