Sanders, Justin ( 2015 )

PD-1171-15
PD-1171-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
September 14, 2015 Transmitted 9/8/2015 1:52:21 PM
Accepted 9/14/2015 10:45:33 AM
ABEL ACOSTA
IN THE COURT OF CRIMINAL APPEALS CLERK
OF TEXAS
JUSTIN SANDERS §
§
V. § CASE NO. 06-14-00079-CR
§
STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
The Appellant in the above-captioned case, through the undersigned attorney
of record, moves the Court for an extension of time in which to file his petition for
discretionary review pursuant to Rules 68.2(c) and 10.5(b) of the Texas Rules of
Appellate Procedure. As grounds therefore, the Appellant would show the Court the
following:
1. The Sixth Court of Appeals issued its memorandum opinion and judgment in
Justin Sanders v. State of Texas, No. 06-14-00079-CR, on August 12, 2015. No
motion for rehearing or en banc reconsideration was filed. Therefore, Appellant’s
petition for discretionary review is due September 11, 2015.
2. The Appellant is requesting an additional 30 days, or until October 12, 2015,
to file his petition for discretionary review.
3. The undersigned counsel was retained last week to represent the Appellant in
filing a petition for discretionary review. Counsel did not represent the Appellant in
Appellant's Motion for Extension of Time Page 1 of 3
the court of appeals. Rather, the Appellant was represented by court-appointed
counsel Craig L. Henry. This case involves a voluminous record and numerous
complex legal issues. Therefore, counsel needs additional time to obtain and review
the record and research the relevant law. This motion is not made for purposes of
delay, but in the interest of justice, to meet counsel’s obligations to her client and this
Court, and to accomplish the design of this appeal, which is to do substantial justice
to Appellant.
4. No previous extensions have been granted in this matter.
Respectfully submitted,
/s/ Gena Bunn
Gena Bunn
State Bar No. 00790323
Holmes & Moore, P.L.L.C.
P.O. Drawer 3267
Longview, Texas 75606
Office No. (903) 758-2200
Facsimile No. (903) 758-7864
Email: gbunn@holmesmoore.com
Appellant's Motion for Extension of Time Page 2 of 3
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing motion was
delivered by United States Mail, to Jerry Rochelle, Bowie County District Attorney,
Bowie County Plaza, 601 Main Street, Texarkana, Texas 75501, on this the 8th day
of September, 2015.
/s/ Gena Bunn
Gena Bunn
Appellant's Motion for Extension of Time Page 3 of 3