Bolen, Chance Douglas ( 2015 )

PD-1464-15 PD-1464-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/11/2015 10:05:41 AM
Accepted 11/12/2015 2:04:36 PM
No. 07-15-00071-CR ABEL ACOSTA
CLERK
CHANCE BOLEN § IN THE COURT OF APPEALS
§
V. § OF THE SEVENTH SUPREME
§
STATE OF TEXAS § JUDICIAL DISTRICT
MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW the Appellant, by and through his counsel, David Crook, and files
this motion for an extension of 30 days or the maximum amount of time possible in
which to file his Petition for Discretionary Review in the above-referenced appeal. In
support of this motion, Appellant would show the Court the following:
I.
On October 14, 2015, the Seventh Court of Appeals, in Appellate No. 07-15-
00071-CR, styled Chance Bolen v. the State of Texas, affirmed the judgment of the Court
below.
II.
The present deadline for filing Appellant’s Petition for Discretionary Review is
November 13, 2015. The Appellant has not requested any extensions with regard to his
P.D.R. prior to this request.
III.
Appellant's request for an extension is based upon the following facts: Counsel
has been spending some time in Shreveport, Louisiana, as Counsel’s 88-year old mother
requires some attention to her affairs regarding her increasing hearing and vision
problems.
November 12, 2015
Prayer
WHEREFORE, appellant prays that the Court grant this motion and extend the
deadline for filing the Appellant’s Petition for Discretionary Review in Appellate No. 07-
15-00071-CR to Monday, December 14, 2015.
Respectfully submitted,
Crook & Jordan
By: /s/David Crook
David M. Crook
PO Box 94590
Lubbock, TX 79493
(806) 744-2082
SBN: 05109530
Telephone: (806) 744-2082
Fax: (806) 744-2083
dcrook@nts-online.net
Attorney for Appellant
CERTIFICATE OF SERVICE
This is to certify that a copy of the above-entitled and numbered motion has been
served on Jeff Ford, attorney for the state, by e-mail, on this the 11th day of November,
2015.
/s/David Crook
DAVID CROOK
Appellant’s M.Xtn.PDR 2