Christmas, Lemarcus Ashontay ( 2015 )

PD-0544&0545&0546-15
PD-0544&0545&0546-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/7/2015 3:42:49 PM
Accepted 5/8/2015 10:46:44 AM
NO. __________________________ ABEL ACOSTA
CLERK
LEMARCUS ASHONTAY § IN THE COURT OF
CHRISTMAS §
§
VS. § CRIMINAL APPEALS
§
STATE OF TEXAS § OF TEXAS
MOTION TO EXTEND TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
Now comes LEMARCUS ASHONTAY CHRISTMAS, Appellant in the above styled and
numbered cause, and moves for an extension of time of 30 days to file a petition for discretionary
review, and for good cause shows the following:
1. On April 14, 2015, the Court of Appeals for the Fourteenth Judicial District at
Houston affirmed appellant's conviction in the matter of LEMARCUS ASHONTAY
CHRISTMAS v. State, under case numbers 14-13-01102-CR, 14-13-01103-CR,
14-13-01104-CR. This petition is therefore due on MAY 14, 2015.
2. Counsel has been unable to complete the petition for the following reasons:
Counsel has recently returned from maternity leave.
3. Defendant is currently incarcerated.
4. No extensions of time to file Petition for Discretionary Review have been granted.
5. No motions for rehearing or en banc considerations have been filed.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully requests an
extension of 30 days, i.e. until June 14, 2015, to file a petition for discretionary review.
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May 8, 2015
Respectfully submitted,
Law Office of Jessica Marie Jaramillo Moreno
2512 1st Street
Rosenberg, Texas 77471
Tel: 281-658-1336
Fax: 281-667-3023
jmjm.esq@gmail.com
By:
Jessica Jaramillo-Moreno
State Bar No. 24078733
Attorney for LEMARCUS ASHONTAY
CHRISTMAS
CERTIFICATE OF SERVICE
This is to certify that on May 07, 2015, a true and correct copy of the above and foregoing
document was served on the District Attorney's Office, Fort Bend County, Texas, by facsimile
transmission to 281-341-4440.
Jessica Jaramillo-Moreno
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