Whitfield, Jeffery Tyrone ( 2015 )

PD-0575-15 IN THE COURT OF CRIMINAL APPEALS OF TEXAS JEFFERY TYRONE WHITFIELD, APPLICANT VS. May 12, 2015 May 12, 2015 THE STATE OF TEXAS FROM THE SEVENTH COURT OF APPEALS AMARILLO, TEXAS NO. 07-14-00086-CR APPEALED FROM COUNTY CRIMINAL COURT ONE DENTON COUNTY, TEXAS (TRIAL NUMBER 2013-04378-A) MOTION TO PERMIT LATE FILING OF APPELLANT’S PETITION FOR DISCRETIONARY REVIEW This motion is brought by JEFFERY TYRONE WHITFIELD, Appellant, and requests that this Court grant this late filing of Appellant’s Petition for Discretionary Review (“PDR”) and in support of which would show the following: I. Appellant’s PDR was due on May 11. 2015. The PDR is complete and has been filed on this date, May 12, 2015, with the Court of Criminal Appeals. II. The due date was erroneously scheduled on the undersigned’s calendar as due May 12, 2015, when in fact it was due May 11, 2015. WHEREFORE, PREMISES CONSIDERED, Appellant, JEFFERY TYRONE WHITFIELD, prays this Court will grant permission to file said PDR. Respectfully submitted, MOTION TO PERMIT LATE FILING OF APPELLANT’S PETITION FOR DISCRETIONARY REVIEW Page 1 /s/ Abe Factor Abe Factor State Bar No. 06768500 Attorney for Appellant FACTOR , CAMPBELL & COLLINS 5719 Airport Freeway Fort Worth, TX 76117 (817) 222-3333 (817) 222-3330 (fax) lawfactor@yahoo.com CERTIFICATE OF SERVICE I, ABE FACTOR, do hereby certify that a true and correct copy of the foregoing MOTION TO PERMIT LATE FILING OF APPELLANT’S PETITION FOR DISCRETIONARY REVIEW has been e- filed to the Denton County District Attorney’s office, Appellate Section, and the State Prosecutor11 on this the 12th day of May, 2015. /s/ Abe Factor Abe Factor MOTION TO PERMIT LATE FILING OF APPELLANT’S PETITION FOR DISCRETIONARY REVIEW Page 2