Tienda, Joe Louis ( 2015 )

PD-0684-15 PD-0684-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 6/4/2015 9:49:48 AM Accepted 6/4/2015 12:09:03 PM ABEL ACOSTA CAUSE NO. CLERK IN THE COURT OF CRIMINAL APPEALS AUSTIN, TEXAS STATE OF TEXAS, Appellant June 4, 2015 V. JOE LOUIS TIENDA, Appellee Petition for Discretionary Review from the Eleventh Court of Appeals Cause No. 11-11-00283-CR and Appeal From the 428™ Judicial District Court Cause No. CR-07-0802 Hays County, Texas STATE'S FIRST MOTION FOR EXTENSION OF TIME IN WHICH TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUSTICES OF THE TEXAS COURT OF CRIMINAL APPEALS: The State files this First Motion for Extension of Time in Which to File the State's Petitionfor Discretionary Review, and in support states: 1. The Eleventh Court Of Appeals rendered judgment in the styled case no. 11-11-00283-CR on May 14, 2015. 2. The State's current deadline for filing her petition is June 15, 2015. 3. This is the State's first motion for extension of time in which to file her petition. 4. The State respectfully requests an extension of approximately thirty days, until July 15, 2015 in which to file her petition. 5. Good cause exists for the State's request for extension of time. The Hays County District Attorney Office Civil Division has undergone major changes in the past months. The undersigned attorney recently assumed full time duties as an attorney for the Department of Family and Protective Services within the District Attorney's office. 6. This extension is not being sought to cause undue delay, but to seek justice. 7. For the foregoing reasons, the State respectfully requests that the Court grant an approximate fifteen day extension for filing the State's Petition for Discretionary Review, until July 15, 2015. ctfully submitted, )berts-Huckaby Assistant Criminal District Attorney Hays County, Texas Hays County Government center 712 South Stagecoach Trail, Ste. 2057 San Marcos, Texas 78666 angie.roberts@co.hays.tx.us (512)393-7600 (512) 393-2246 fax State Bar No. 24081797 Verification The foregoing Appellant Motion for Extension of Time in Which to File Petition for Discretionary Review was subscribed and sworn to before me by Angie D. Roberts-Huckaby on this the 15th day of June 2015. Angie D. Roberts-Huckaby RHONDA WIEDERSTEIN my COMMISSION EXPIRE'- September 9.2018 Notary Public tate of Texas CERTIFICATE OF SERVICE I certify that on June 15, 2015, I served the above motion by email to Mr. Chevo Pastrano at chevo@pastranolaw.com, in accordance with the Texas Rules of ApzfEK^ate Procedure. ngiel). Roberts-Huckaby