Cochran, Mitchell Dean ( 2015 )

6l^A/0.-f FILED IN PD-0793-15 COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/18/2015 4:08:46 PM December 18, 2015 ^/•ruFte Accepted 12/19/2015 11:36:13 AM ABELACOSTA, CLERK PD 0793-15 "j^p^y ABEL ACOSTA CLERK IN THE COURT OF CRIMINAL APPEALS MITCHELL DEAN COCHRAN VS. THE STATE OF TEXAS MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING TO THE HONORABLE JUDGES OF SAID COURT: I. COMES NOW, Appellant in the above styled case, and makes and files this his request for an extension of time to file his motion to extend time to file a motion for rehearing and would show unto the Court the following: COURT BELOW: Tenth Court of Appeals CAUSE NUMBER BELOW: NO. 10-14-00013-CR DATE FOR PETITION OF DISCRETIONARY REVIEW REFUSED: 12-9-15 PRESENT DEADLINE FOR FILING APPELLANTS' PDR: 12-25-15 Mitchel Dean Cochran DAYS REQUESTED BY THIS EXTENSION: 20 days from the date motion is due (1-14-16) DATE TO WHICH EXTENSION IS REQUESTED: 1-13-16 NUMBER OF EXTENSIONS PREVIOUSLY GRANTED: None I. The Appellee's request is based upon the following reasonable explanation of the need for additional time, within the personal knowledge of Charles W. McDonald, the attorney signing this motion, T.R.A.P. 10.5(b), namely: II. Due to the upcoming holidays, Counsel is scheduled to be out of the office until January 4, 2016 and requests an extension to January 14, 2016. III. WHEREFORE, this Attorney for the Appellant prays that the Court grant this motion and extend the time and deadline for the filing of Appellant's motion for rehearing, or the Court grant such additional time as is just and proper. Respectfully submitted, /s/Charles W. McDonald Charles W. McDonald ATTORNEY AT LAW 2024 Austin Avenue Waco, Texas 76701 (254) 752-9901 FAX: (254) 754-1466 SBOTNO. 13538800 Mitchel Dean Cochran CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of this brief was served electronically on December 18, 2015 to: (1) counsel for the State, Sterling Harmon, sterkng.harmon@co.mclennan.tx.us; and (2) the State Prosecuting Attorney, lisa.mcminn@SPA.texas.gov. IslCharles W. McDonald Charles W. McDonald Mitchel Dean Cochran