NO._______________________________ 

IN THE 

COURT OF CRIMINAL APPEALS 

OF TEXAS 

EX PARTE WENDI ANN TILLMAN 

Applicant 

vs. 

THE STATE OF TEXAS 

Respondent 

ON APPLICATION FOR WRIT OF HABEAS CORPUS 

TO THE 368TH JUDICIAL DISTRICT COURT OF WILLIAMSON COUNTY TEXAS 

NO. 

STATE’S MOTION FOR EXTENSION OF TIME

Jana Duty 

District Attorney 

Williamson County, Texas 

John C. Prezas 

State Bar No: 24041722 

Assistant District Attorney 

405 Martin Luther King, Box 1 

 Georgetown, Texas 78626 

 (512) 943-1234 

 (512) 943-1255 (fax) 

 jprezas@wilco.org

WR-83,577-01

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 7/14/2015 1:33:32 PM

Accepted 7/15/2015 7:56:45 AM

ABEL ACOSTA

CLERK

 RECEIVED COURT OF CRIMINAL APPEALS 7/15/2015 ABEL ACOSTA, CLERK 
NOW COMES THE STATE OF TEXAS, by and through her Assistant 

District Attorney, John C. Prezas, and moves the Court, pursuant to Article 11.07 

of the Texas Code of Criminal Procedure and Tex. R. App. Pro. 73.5, to allow the 

parties additional time to investigate and submit proposed findings of fact and 

conclusions of law, as well as any supporting affidavits or documentation to the 

trial court. In support of its motion, the State would show the Court the following:

1. Wendi Ann Tillman (hereinafter “Applicant”) filed an application for a writ of 

habeas corpus in cause 06-1062-K368 in the 368th Judicial District Court in 

Williamson County Texas, the trial court, on February 17, 2015.

2. The State filed its answer in that cause on February 27, 2015.

3. The trial court entered an Order Designating Issues on March 3, 2015.

4. Applicant filed her proposed findings of fact and conclusions of law on May 12, 

2015.

5. The State recently submitted a motion for additional time to the trial court, 

seeking an order granting the parties until September 26, 2015, to submit 

proposed findings of fact and conclusions of law, as well as any supporting 

affidavits or documentation, on or before July 14, 2015.

6. That proposed due date falls outside of the 180 day time period contemplated 

by Tex. R. App. Pro. 73.5. Therefore, the State has filed this motion in hopes 
that this Court will allow for the additional time it has requested from the trial 

court to obtain affidavits responsive to the issues designated by the trial court.

7. The State intends to use the additional time to obtain affidavits from Mr. Greg 

Terra, Mr. Dario Bargas, and Ms. Amber Hinson, the attorneys who represented 

applicant at various stages of the case and whom she argues have rendered her 

ineffective assistance of counsel.

8. Mr. Prezas has corresponded extensively with Mr. Terra and knows Mr. Terra 

to be preparing an affidavit currently. Mr. Terra has asked for additional time 

to do so.

9. Mr. Prezas has also corresponded with Mr. Bargas who is currently reviewing 

his file regarding this matter. Mr. Prezas recently learned of Ms. Hinson’s 

involvement and is seeking further information from her as well.

10. Mr. Prezas believes these additional affidavits and additional information will 

significantly assist the trial court in evaluating applicant’s claims and resolving 

the issues it has designated.
WHEREFORE, PREMISES CONSIDERED, the State of Texas respectfully 

requests that this Court grant its motion for an additional time to provide these 

affidavits and information related thereto to the trial court and designate some date 

after September 26, 2015, by which the trial court must provide to this Court its 

findings of fact and conclusions of law.

Respectfully submitted,

Jana Duty

District Attorney

Williamson County, Texas

/s/ John C. Prezas

John C. Prezas

Assistant District Attorney

State Bar Number 24041722

405 Martin Luther King #1

Georgetown, Texas 78626

(512) 943-1248

(512) 943-1255 (fax)

jprezas@wilco.org

Certificate of Service

This is to certify that on July 14, 2015, a copy of the foregoing motion has 

been sent to Appellant by certified mail to Wendi A. Tillman at the following 

address: William P. Hobby Unit, 742 FM 712, Marlin, TX 76661.

/s/ John C. Prezas

John C. Prezas