Rodriguez, Hector L. ( 2015 )

PD-1479-15 PD-1479-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/13/2015 2:52:16 PM
November 16, 2015 Accepted 11/16/2015 2:58:15 PM
NO. ABEL ACOSTA
CLERK
IN THE
COURT OF CRIMINAL APPEALS
OF TEXAS
NO. 01-12-00970-CR
IN THE COURT OF APPEALS
FOR THE
FIRST JUDICIAL DISTRICT OF TEXAS
HOUSTON, TEXAS
THE STATE OF TEXAS § APPELLEE
§
V. §
§
HECTOR L. RODRIGUEZ § APPELLANT
APPEAL FROM COUNTY COURT AT LAW NO. 5
HARRIS COUNTY, TEXAS
TRIAL COURT NO. 1726063
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT'S PETITION FOR DISCRETIONARY REVIEW
__________________________________________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes, Hector L. Rodriguez, Appellant in the above entitled and
numbered cause, by and through his attorney of record, W. Troy McKinney, and
submits this Motion for Extension of Time to file Appellant's Motion for Rehearing
until December 16, 2015. For good cause, Appellant shows as follows.
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1. This Court issued its opinion on July 25, 2015. On August 17, 2015,
Appellant’s motion for rehearing was filed and it was overruled on October 15, 2015.
This petition for discretionary review is due to be filed on or about November 16,
2015. This is Appellant's first request for an extension of time to file Appellant's
Petition for Discretionary Review.
2. The last thirty days, Appellant's counsel has had an extremely heavy trial
court docket, and several out of town court settings.
3. Furthermore, counsel was a speaker at a seminar in Oklahoma City and
Corpus Christi, Texas.
4. This Motion is not made for delay, but to see that justice is done.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the deadline
for filing of Appellant’s Motion for Petition for Discretionary be extended to December
16, 2015.
Respectfully submitted,
SCHNEIDER & McKINNEY, P.C.
/s/ W. Troy McKinney
_______________________
W. Troy. McKinney
T.B.C. No. 13725020
440 Louisiana
Suite 800
Houston, Texas 77002
713-951-9994
FAX 713-224-6008
Email: wtmhousto2@aol.com
ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the attached and foregoing
document has been served on Harris County District Attorney’s Office, on this the 13th
day of November, 2015.
/s/ W. Troy McKinney
____________________________
W. Troy McKinney
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