IN THE COURT OF CRIMINAL APPEALS

EX PARTE § 

§ 

§ NO. C-2-010289-0764908-B 

§ 

TIMOTHY RANDAL THOMPSON § 

MOTION FOR EXTENSION OF TIME

FOR SUBMISSION OF WRIT RECORD

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

COMES NOW, the Criminal District Court No. 2 of 

Tarrant County Texas and moves this Court to grant a onehundred and eighty (180) day extension of time for 

resolution of the issues and to submit the writ record in 

this case. The following allegations are made in support 

of this motion:

I.

 The applicant was convicted by a jury of the offense 

of murder and sentenced to twenty-five years’ confinement 

on April 20, 2001. See Judgment.

II.

On August 19, 2014, the applicant (represented by the 

Hon. Robert N. Udashen and the Hon. Bruce Anton) filed an 

WR-63,871-03

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 2/11/2015 3:07:27 PM

Accepted 2/12/2015 8:15:52 AM

ABEL ACOSTA

CLERK

 RECEIVED COURT OF CRIMINAL APPEALS 2/12/2015 ABEL ACOSTA, CLERK 
application for writ of habeas corpus alleging that he 

was denied effective assistance of counsel. See

Application. The trial court timely designated this 

issue for future resolution on September 8, 2014. See

Order Designating Issues. The trial court’s 180-day 

deadline for resolving this issue is February 17, 2015. 

See Tex. R. App. P. 4 & 73.5.

III.

The trial court conducted live hearings on January 

21, 2015, and January 30, 2015. The applicant’s trial 

counsels, the Hon. Leslie Johns and the Hon. Leon Haley, 

testified regarding their representation.

IV.

In conjunction with this writ application, the 

applicant filed a motion for forensic testing of the 

firearm used in his case. See Motion for Forensic 

Testing. The Code of Criminal Procedure permits a trial 

court to order additional forensic testing to resolve 

controverted issues. See Tex. Code Crim. Proc. art. 

11.07, §3(d). The trial court granted the applicant’s 
request for forensic testing on January 30, 2015. See

Modified Order.

V.

Additional time beyond the 180-day deadline is needed 

so that forensic testing can be completed, any additional 

hearing can be conducted, and each side can prepare its

proposed findings of fact and conclusions of law. 

Counsels for the applicant (the Hon. Robert N. Udashen 

and the Hon. Bruce Anton) and the State (the Hon. Steven 

Conder) agree that additional time is needed to resolve 

the issues raised in this application

VI.

The trial court requests that this Court grant a one 

hundred and eighty (180) day extension of time for 

resolution of the issues and submission of the writ 

record in this application. If this extension is 

granted, the writ record will be submitted on or before 

August 16, 2015.
WHEREFORE, PREMISES CONSIDERED, the trial court prays 

that this Court grant a one hundred and eighty (180) day 

extension for submission of the writ record in this 

application to August 16, 2015.

Respectfully submitted,

/s/ CHARLES P. REYNOLDS

CHARLES PATRICK REYNOLDS

Judicial Staff Counsel and 

Post-Conviction Magistrate

Tarrant County, Texas

401 W. Belknap

Fort Worth, Texas 76196

(817) 884-2326

Fax (817) 884-2312

State Bar No. 00789580

CERTIFICATE OF SERVICE

A true copy of the above Motion for Extension of Time 

for Submission of Writ Record has been transmitted to the 

applicant’s counsel, the Hon. Robert N. Udashen and the 

Hon. Bruce Anton, 2311 Cedar Springs Road, Suite 250, 

Dallas, Texas 75201, and hand-delivered to the State’s 

counsel, the Hon. Steven W. Conder, on this, the ___ day 

of February, 2015.

/s/ CHARLES P. REYNOLDS

CHARLES PATRICK REYNOLDS