Escobar, Paul Angelo ( 2015 )

PD-0609-15 RECEIVED IN No. COURTOFCRIMINW APPEALS MAY 18 2S15 Court of Appeals No. 05-13-01562-CR Trial Court No. F1262912-Q PAUL ANGELO ESCOBAR, * IN THE COURT OF Petitioner * CRIMINAL APPEALS VS. * OF TEXAS FILED IN STATE OF TEXAS, * IN " 0F CRiM^AL APPEALS MAY 22 2G15 Respondent * AUSTIN, TEXAS Abel Acosta, C/erk FIRST MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW, the Petitioner in the above-styled and numbered cause, and moves the Court to extend the time for filing the Petition for Discretionary Review, and in accordance with the appellate rules, submits the following facts: 1. Trial Court: 204™ Judicial District Court 2. Date of appealable order: 10-11-13 3. Trial Court Cause number: F12-62912-Q + - 4. Paul Angelo Escobar vs. State of Texas 5. Offense for which Appellant was convicted: Aggravated Robbery 6. Punishment assessed: 20y 7. Date Motion for New Trial filed: 10-29-13 8. Date Notice of Appeal filed: 10-29-13 9. Fifth District Court of Appeals, Dallas, Texas 10.Appellate no. 05-13-01562-CR; Paul Angelo Escobar 11.Date of appellate opinion and judgment: March 10, 2015 12.Deadline for filing petition for discretionary review: April 9, 2015 13. Length of time requested for the extension: 30 days 14. The number of extensions of time which have been granted previously regarding this item: 0 15.The facts relied upon to reasonably explain the need for an extension: a. Counsel timely mailed a copy of the opinion and explanation of appellate rights to Appellant by certified mail. However, it was returned to counsel unclaimed on today's date, March 24, 2015, apparently because Appellant was transferred to a different unit. Counsel has now resent the opinion and explanation of appellate rights but due to the delay, Appellant needs additional time to prepare a petition for discretionary review. WHEREFORE, PREMISES CONSIDERED, the Petitioner prays that this Honorable Court will extend the time within which to file the petition for discretionary review. Respectfully submitted, Paul Angelo Escobar No. 1892438 Torres Unit 125 Private Road 4303 Hondo, Texas 78861 Pro se Petitioner CERTIFICATE OF SERVICE I hereby certify that the foregoing Motion was served on the Appellate Section, Dallas County District Attorney's Office, 133 N. Riverfront Blvd., LB 19, Dallas, Texas 75207, by placing it in the U.S. mail on 4r . T&