Turner, Jimmy ( 2015 )

PD-0893-15
PD-0893-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/17/2015 1:48:59 PM
Accepted 7/17/2015 4:43:03 PM
ABEL ACOSTA
CLERK
IN THE COURT OF CRIMINAL APPEALS
FOR THE STATE OF TEXAS
AUSTIN, TEXAS
JIMMY TURNER
Appellant
V. NO. 04-13-00886-CR
THE STATE OF TEXAS
Appellee
Petition in Cause No. 2031-CR-6595-B and the Court of Appeals for the Fourth District of
Texas.
APPELLANT'S MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW Appellant, JIMMY TURNER, and pursuant to Rule 10.1 and Rule 10.5 of
the Texas Rules of Appellant Procedure, and files this Motion to Extend Time to File Petition for
Discretionary Review. In support of said motion, the Defendant would show as follows:
I.
On June 17, 2015, the Court of Appeals for the Fourth District of Texas affirmed the
judgment in Jimmy Turner v. The State of Texas, Cause No. 04-13-00886-CR. This cause had
been appealed from the 186^ Judicial District ofBexar County, Texas. Trial Court Number
2013-CR-6595-B.
July 17, 2015
II.
The Petition for Discretionary Review is due on July 17, 2015. The Appellant has not
requested previous extensions in which to file Petition.
III.
Appellant would show that the following are reasonable explanations for the requested
extension:
Appellant is filing a Petition for Discretionary Review Pro Se.
In order to have sufficient time to prepare Petition for Discretionary Review, Appellant
would request an extension to file Petition for Discretionary Review to October 7,2015.
Counsel consulted with the Bexar County Appellate Division and they have no objection
to this request.
WHEREFORE, PREMISES CONSIDERED, Appellant prays the court grant this motion
and allow Petition for Discretionary Review to be filed on October 7,2015.
Respectfully submitted,
LAW OFFICE OF PAMELA J. LAKATOS
PAMELA J.LAKlj^TOS
TEXAS BAR CARD #04825600
3191 MEDICAL CENTER DRIVE APT 23105
MCKINNEY, TEXAS 75069
COUNSEL FOR APPELLANT
JIMMY TURNER
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing motion was delivered to
Bexar County District Attorney's Office, via email on July, 17,2015.
PAMELA J. LAKATOS
r
AFFIDAVIT OF PAMELA J. LAKATOS IN SUPPORT OF
APPELLANT'S MOTION FOR ENLARGEMENT OF TIME
wrnnN which t o file appellant's brief
STATE OF TEXAS §
COUNTY OF COLLIN §
BEFORE ME, the undersigned authority, personally appeared PAMELA J. LAKATOS,
known to me to be the attorney ofrecord for JIMMY TURNER, in the capacity stated, and who
after being duly sworn, deposed and said:
"My name is PAMELA J. LAKATOS. I am over the age of 21 years. I have personal
knowledge of every statement herein and am fully competent and authorized to testify to these
matters. I am licensed to practice law in the State of Texas. I am the attorney of record for
JIMMY TURNER.
"I have read Appellant's Motion for Extension of Time Within Which to File Petition for
Discretionary Review, and I swear and affirm that all of the information contained therein is true
and correct to my knowledge."
FURTHER AFFIANT S AYETH NOT,
Xi) _ . r\
PAMELA J. LAKATOS
SUBSCRIBED AND SWORN TO BEFORE ME the undersigned authority on this the
Bk. day ofJuly 2015.
NOTARY PUBLIC IN AND FOR
ROBERTS THE STATE OF TEXAS
Notary Public
STATE OF TEXAS
MyComm. Esp.August 10.2017