Gaona, Valentin ( 2015 )

PD-0383-15
PD-0383-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
April 3, 2015 Transmitted 4/3/2015 12:20:27 PM
Accepted 4/3/2015 1:39:41 PM
NO. 13-14-00083-CR ABEL ACOSTA
CLERK
VALENTIN GAONA § IN THE
§
VS. § COURT OF CRIMINAL APPEALS
§
STATE OF TEXAS § TRAVIS COUNTY, TX
MOTION TO EXTEND TIME TO FILE PDR
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes VALENTIN GAONA Appellant in the above styled and numbered cause,
and moves this Court to grant an extension of time to file PDR, pursuant to the Texas Rules of
Appellate Procedure, and for good cause shows the following:
1. This case is on appeal from the 94TH Judicial District Court of NUECES County,
Texas.
2. The case below was styled the STATE OF TEXAS vs. VALENTIN GOANA, and
numbered 13-CR-2947-C.
3. Appellant was convicted of Evading with a Vehicle and Sentencd to32 years TDC
on January 22, 2014.
4. Notice of appeal was given on or about January 30, 2014
5. The clerk's record was filed on May 13, 2014; the reporter's record was filed on
March 20, 2014.
6. The appellate brief was filed on or about
7. The appellate brief is presently due on or about October 17, 2014.
8. State’s Brief was filed December 1, 2014.
9. The Court of Appeals issued an opinion on February 19, 2015
10. A Petition for Discretionary Review was due on March 19, 2015 and Deadline for
an extension is April 3, 2015.
11. Defendant is currently incarcerated at the WILLACY Unit, 1695 S Buffalo Dr.
Raymondville, TX 78580.
11. Appellant relies on the following facts as good cause for the requested extension:
TO ALLOW DEFENDANT TIME TO FILE ‘PRO SE’ PDR.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this
Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the
Court may deem appropriate.
Respectfully submitted,
GRAHAM LEGAL SERVICES
3206 Reid Dr 105
Corpus Christi, TX 78404
Tel: (361) 723-1530
Fax: (361) 723-1531
By:/s/CORETTA GRAHAM
Coretta T. Graham
State Bar No. 50511851
Appeal Counsel for VALENTIN GOANA
CERTIFICATE OF SERVICE
This is to certify that on April 3 2015, a true and correct copy of the above and foregoing
document was served on the District Attorney's Office, Nueces County, 901 Leopard rm, 206,
CC, TX 78401, by hand delivery/email.
/s/CORETTA GRHAM
Coretta T. Graham, Appeal Counsel