Maza, Richard Lee ( 2015 )

PD-0873-15
PD-0873-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/13/2015 6:03:52 PM
July 15, 2015 Accepted 7/15/2015 3:51:21 PM
ABEL ACOSTA
CLERK
NO. 13-14-00128-CR
RICHARD LEE MAZA § IN THE COURT OF
§
VS. § CRIMINAL APPEALS
§
STATE OF TEXAS § OF TEXAS
MOTION TO EXTEND TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
Now comes Richard Lee Maza, Appellant in the above styled and numbered cause,
and moves for an extension of time of 30 days to file a petition for discretionary review,
and for good cause shows the following:
1. On June 11, 2015, the Court of Appeals affirmed appellant's conviction.
Richard Lee Maza v. State, 13–14–00128–CR, 2015 WL 3637821, (Tex. App. — Corpus
Christi/Edinburg, no pet. h.). This petition is therefore due on July 13, 2015.
2. Counsel has been unable to complete the petition for the following reasons:
Today I was called by surprise to a hearing in the 410th Judicial District Court,
Montgomery County, Texas. I worked approximately 12 hours yesterday, mostly on
appellate matters. I worked about 18 hours the day before that on appellate matters. On
Friday, I had been set for docket call early that morning, and worked past midnight on
appellate matters and having jail conferences with clients I had not met yet. I prepared for
trial Wednesday and Thursday, the latter day past midnight. I am appealing rejected habeas
corpus relief in another case, which was rejected on Tuesday. If it is not given in a few
days, her right to release will be completely moot.
3. Defendant is currently incarcerated.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully requests an
extension of 30 days, i.e. until August 12, 2015, to file a petition for discretionary review.
Respectfully submitted,
Bob Mabry, Attorney at Law, PLLC
304 North Main Street #6
Conroe, Texas 77301-3002
(936) 228-7796
Fax 1-866-394-3113
By: /s/ Bob Mabry
Bob Mabry
State Bar No. 12750980
mabry.bob@gmail.com
Attorney for Richard Lee Maza
CERTIFICATE OF SERVICE
This is to certify that on July 13, 2015, a true and correct copy of the above and
foregoing document was served on the District Attorney's Office, San Patricio County,
P.O. Box 1393 Sinton, TX 78387, by fax to (361) 364-9490 before 5 PM Central Daylight
Time.
/s/ Bob Mabry
Bob Mabry