Salmeron, Elmer O.

WR-81,503-02 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 2/9/2015 4:53:33 PM Accepted 2/10/2015 8:02:23 AM

ABEL ACOSTA CAUSE NO. WR-81,503-02 CLERK

IN THE COURT OF CRIMINAL APPEALS RECEIVED

COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS 2/9/2015

AT AUSTIN ABEL ACOSTA, CLERK

__________________________________________________

ON APPEAL FROM APPLICATION FOR A WRIT OF HABEAS CORPUS

CAUSE NO. W11-00773-M(B)

194th DISTRICT COURT DALLAS COUNTY, TEXAS

___________________________________________________

ELMER SALMERON

APPLICANT,

V. STATE OF TEXAS,

APPELLEE ________________________________________________

MOTION FOR EXTENSION OF TIME TO FILE FINDINGS OF FACT AND

CONCLUSIONS OF LAW AFTER HEARING

_________________________________________________

BRUCE ANTON STATE BAR NO. 01274700 SORRELS UDASHEN & ANTON 2311 Cedar Springs #250 Dallas, Texas 75201 214/468-8100 214/468-8104 (fax) [email protected]

COMES NOW, Bruce Anton, counsel for Applicant, Elmer Salmeron, in this cause, and moves this court to issue an extension of time to file his findings of fact and conclusions of law, and in support thereof would show the court as follows:

I.

This writ of habeas corpus is currently pending in the 194th District Court of Dallas County, Texas. A bench warrant was issued for Applicant to appear at a hearing March 6, 2015. After the hearing, counsel proposes to submit findings of fact and conclusions of law in regard to Applicant’s claim that his plea was involuntary and that which it deems relevant and appropriate to the disposition of Applicant’s claim for habeas corpus relief.

II.

Counsel is diligently pursuing this matter, however, an additional 60 days is required to complete the findings.

III.

No previous extensions have been requested.

IV.

The facts relied upon to show good cause for this request for extension are recited above.

WHEREFORE, PREMISES CONSIDERED, the undersigned attorney requests this court to grant an extension of time of 60 days to file findings of fact and conclusions of law.

RESPECTFULLY SUBMITTED, /s/ Bruce Anton BRUCE ANTON STATE BAR NO. 01274700 SORRELS UDASHEN & ANTON 2311 Cedar Springs #250 Dallas, Texas 75201 214/468-8100 214/468-8104 (fax) [email protected]

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of Appellant’s motion for extension to file findings of fact and conclusions of law was delivered via U.S. Mail to Dallas County District Attorney’s Office, 133 N. Riverfront, Dallas, Texas 75207 on the 9th day of February, 2015.

/s/ Bruce Anton BRUCE ANTON