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 N o. 2 of Tarrant County Texas and moves this Court to grant a one

hundred 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.
T he 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 ) fil ed 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 CLERKapplication for writ of habeas corpus alleging that he was denied effective assistance of counsel. See Application. T he trial court timely designated this issue for future resolution on September 8 , 2014. See Order Designating Issues. The trial c ourt’s 180

- day deadline for resolving this issue i s February 17 , 2015.
See Tex. R. App. P. 4 & 73.5.

III. The trial court conducted live hearing s on January 21, 2015, and January 30, 2015 . The applicant’s trial counsel s , the Hon. Leslie Johns and the H on. Leon Haley, testified regarding their representation.

IV. In conjunction with t his 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’srequest for forensic testing on January 30, 2015. See Modified Order.

V. Ad ditional 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. Ro bert 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

V I
. The trial court requests that this Court grant a one hundred and eighty (18 0) day e xtension 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 ( 18 0 ) 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 transmit ted 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. Steve n W. Conder, on this, the

___ day of February , 2015

. /s/ CHARLES P. REYNOLDS CHARLES PATRICK REYNOLDS