Cochran, Mitchell Dean ( 2015 )

PD-0793-15 PD-0793-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS June 29, 2015 Transmitted 6/26/2015 1:04:12 PM Accepted 6/29/2015 3:14:29 PM ABEL ACOSTA PD ______________ CLERK IN THE COURT OF CRIMINAL APPEALS ___________________________________________________ MITCHELL DEAN COCHRAN VS. THE STATE OF TEXAS ___________________________________________________ MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW ____________________________________________________ TO THE HONORABLE JUDGES OF SAID COURT: I. COMES NOW, Appellant in the above styled case, and makes and files this his request for an extension of time to file his PDR and would show unto the Court the following: COURT BELOW: Tenth Court of Appeals CAUSE NUMBER BELOW: NO. 10-14-00013-CR DATE FOR PETITION OF DISCRETIONARY REVIEW REFUSED: None PRESENT DEADLINE FOR FILING APPELLANTS’ PDR: 6-26-15 Mitchel Dean Cochran 1 DAYS REQUESTED BY THIS EXTENSION: 30 DATE TO WHICH EXTENSION IS REQUESTED: 7-26-15 NUMBER OF EXTENSIONS PREVIOUSLY GRANTED: None I. The Appellee’s request is based upon the following reasonable explanation of the need for additional time, within the personal knowledge of Charles W. McDonald, the attorney signing this motion, T.R.A.P. 10.5(b), namely: II. Counsel’s daughter was hospitalized under emergency conditions on June 4, 2015, requiring a week-long trip to Los Angeles. Counsel’s father passed away unexpectedly in a car wreck on June 11, 2015. III. WHEREFORE, this Attorney for the Appellant prays that the Court grant this motion and extend the time and deadline for the filing of Appellant’s brief, or the Court grant such additional time as is just and proper. Respectfully submitted, /s/________________________ Charles W. McDonald ATTORNEY AT LAW 2024 Austin Avenue Waco, Texas 76701 (254) 752-9901 FAX: (254) 754-1466 SBOT NO. 13538800 Mitchel Dean Cochran 2 CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the above and foregoing instrument was served upon Abelino “Abel” Reyna, McLennan County Criminal District Attorney, 219 N. Sixth Street, Suite 200, Waco, Texas 76701-1363, according to rule and law, this 26th day of June, 2015. /s/___________________________ Charles W. McDonald Mitchel Dean Cochran 3