PD-0401-15 PD-0401-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 4/8/2015 10:31:44 PM Accepted 4/15/2015 12:59:34 PM ABEL ACOSTA COURT OF CRIMINAL APPEALS CLERK

PD-_______-15 State of Texas, Appellant, v. Marcus Lee Holmquist, Appellee.

On Discretionary Review from No. 05-13-01388-CR Fifth Court of Appeals, Dallas On Appeal from No. CR13-0496 204th District Court, Dallas County Motion to Extend Time to File Petition for Discretionary Review PATRICK SHORT State Bar Card No. 21216900 LAW FIRM OF PATRICK SHORT White Hills Drive Rockwall, Texas 75087 Telephone: (972) 771-1441 Facsimile: (972) 771-0377 [email protected] Attorney for Appellee April 15, 2015 To the Honorable Judges of the Court of Criminal Appeals: Appellee Marcus Lee Holmquist moves for an extension of time of 30 days to file a petition for discretionary review: 1. On February 5, 2015, in State v. Holmquist, 05-13-01388-CR, the County Court at Law in Rockwall County denied the appellee’s motion to suppress evidence.

2. The petition for discretionary review is due on April 9, 2015.

3. For good cause, Appellant asks for an extension of 30 days to file the petition for discretionary review, i.e., until May 9, 2015.

4. No previous extension to file the petition for discretionary review has been filed.

5. Appellant relies on the following facts as good cause for the requested extension: undersigned attorney Patrick Short just completed a two day criminal jury trial involving a Driving While Intoxicated case in Cause Number CR14-0210 before the County Court at Law in Rockwall County in the State of Texas v. Michelle Hill.

6. Further, Patrick Short has the following briefs or other pleadings due soon: • Response to a traditional and no-evidence motion for summary judgment in Oliver v. Lilley, 048-267871-13, 48th Judicial District in Tarrant County, due April 26, 2015.

Page 2 of 4 • Response to a motion to strike the testimony of an expert in Oliver v. Lilley, 048-267871-13, 48th Judicial District in Tarrant County, due April 26, 2015.

• Plaintiff’s traditional motion for summary judgment in Oliver v. Lilley, 048-267871-13, 48th Judicial District in Tarrant County.

• Preparation for a jury trial that is to being April 14, 2015 styled the State of Texas v. Ryan Houston Hughes, CR14-0025, in the Rockwall County Court at Law.

7. This Motion is not filed for purposes of delay, but so that justice may be served.

Prayer Appellant prays that this Court grant this motion for an extension of time to file a petition for discretionary review.

Respectfully submitted,

/S/ Patrick Short PATRICK SHORT State Bar Card No. 21216900 LAW FIRM OF PATRICK SHORT White Hills Drive Rockwall, Texas 75087 Telephone: (972) 771-1441 Facsimile: (972) 771-0377 [email protected] ATTORNEY FOR APPELLEE

Page 3 of 4 Certificate of Service I certify that on April 8, 2015, a true and correct copy of this document was served. See Tex. Rule App. Proc. 9.5 (2014) and 68.11 (2014).

Kenda Culpepper Criminal District Attorney Rockwall County Government Center 1111 E. Yellow Jacket Ln.

Suite 201 Rockwall, TX 75087 Ph: (972) 204-6800 Fx: (972) 204-6809

Jeff Shell Chief Appellate Section Rockwall County Government Center 1111 E. Yellow Jacket Ln.

Suite 201 Rockwall, TX 75087 Ph: (972) 204-6800 Fx: (972) 204-6809

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