Martinez, Rhonald ( 2015 )

PD-0237-15 PD-0237-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/2/2015 11:03:32 AM Accepted 3/2/2015 3:01:09 PM ABEL ACOSTA NO._________________ CLERK IN THE COURT OF CRIMINAL APPEALS OF TEXAS RHONALD MARTINEZ Petitioner March 2, 2015 v. THE STATE OF TEXAS Respondent Petition is in Cause No. 1253416D from the 297th Criminal District Court of Tarrant County, Texas, and Cause No. 02-13-00610-CR in the Court of Appeals for the Second District of Texas MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF APPEALS: COMES NOW, Rhonald Martinez, Petitioner, and requests that this Court grant an extension of time for filing of Petitioner’s Petition for Discretionary Review, and in support of which would show the following: I. Petitioner’s Petition for Discretionary Review is due on or before March 2, 2015. The time for extension requested is thirty (30) days. 1 II. Because of an unusually heavy caseload consisting of both jury trials as well as other appellate obligations, counsel for Petitioner has been unable to complete said Petition; as a result of trial preparation and actual trial, counsel for Petitioner has been unable to devote a sufficient amount of time to the preparation of said Petition. Counsel for Petitioner reasonably believes that the Petitioner for Discretionary Review will be filed with this Court within 30 (30) days of the March 2, 2015, due date. III. No previous “Motion to Extend Time to File Petition for Discretionary Review” has been granted or requested. IV. The Petitioner is incarcerated. WHEREFORE, PREMISES CONSIDERED, Rhonald Martinez, Petitioner, prays this Court will grant an extension of thirty (30) days for Petitioner to file said Petition for Discretionary Review. Respectfully submitted, /s/Abe Factor Abe Factor TBN: 06768500 Factor, Campbell & Collins Attorneys at Law 5719 Airport Freeway Fort Worth, Texas 76117 Phone: (817) 222-3333 Fax: (817) 222-3330 Attorney for Appellant Rhonald Martinez 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been furnished to counsel for the State’s Prosecuting Attorney and the Tarrant County District Attorney by a manner compliant with the Texas Rules of Appellate Procedure, on this 2nd day of March, 2015. /s/Abe Factor Abe Factor 3