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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 MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL

APPEALS:

NOW COMES Petitioner, 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 respectfully requests a forty (40) 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 motion 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 dose 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

CLERK
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Undersigned Counsel has the following judicial 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 for the Western 

District of Texas, when the Order granting Petitioner’s Discretionary 

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-CR-00420 in the United 

States 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-1-

DC-14-302194 in the 147th District Court of Travis County, Texas. Wherein 

she represents a victim in a capital murder case. 

6. Undersigned counsel has a Plea deadline on March 9, 2015 in United States 

of America vs. Kunlin Hsieh, Cause No. 14-CR-00641 in the United States 

District Court for the Western District of Texas. An ITAR and EAR case.

7. Undersigned counsel is set for Docket Call and Rearraignment on March 12, 

2015 in United States of America vs. Kunlin Hsieh, Cause No. 14-CR-00641

in the United States District Court for the Western District of Texas.
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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-CR-00420 in the United States District 

Court for the Western District of Texas, that is due on March 13, 2015. One 

Count was acquitted and the government’s theory on Count Three varied

fatally from the indictment as well as the Court declined to provide a proper 

and requested jury instruction to the jury on Count 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-CR-00641 in the 

United States District Court for the Western District of Texas.

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-CR-2741-W3 in the 144th 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-CR-00221 in 

the United States District Court for the Northern District of Georgia. 
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12. Undersigned counsel is preparing for and is set for a Motions hearing on 

March 31, 2015 in Ex Parte James Moore, Cause No 00-188-K26 in the 26th

Judicial District Court, Williamson County, Texas.

13. Undersigned counsel is investigating discovery and preparing replies to 

responses to pretrial motions in United States of America v. Curtis DeBerry, 

Cause No. 14-CR-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 29th 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 White Collar Crime 

Defense College on March 12-15, 2015 in St. Pete Beach, Florida.
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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 RELIEF

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays 

that this Honorable Court grant him an additional forty (40) days to and including 

April 15, 2015 to file his brief and for any other relief under this Court’s 

supervisory power.

Respectfully submitted:

CYNTHIA E. ORR

Bar No. 15313350

GOLDSTEIN, GOLDSTEIN & HILLEY

310 S. St. Mary’s St.

29th Floor Tower Life Building

San Antonio, Texas 78205

210-226-1463

210-226-8367 facsimile

By:___/s/ Cynthia E. Orr______

CYNTHIA E. ORR

Attorney for Petitioner,

JON THOMAS FORD
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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, Assistant Criminal District Attorney, 

jay.brandon@bexar.org, on this the 26th day of February, 2015.

By: _/s/Cynthia E. Orr________

CYNTHIA E. ORR