Craver, Anthony Carl ( 2015 )

* PD-0825-15 PD-0825-15 COURT OF CRIMINAL APPEALS FILED IN AUSTIN, TEXAS COURT OF CRIMINALAPPEALS Transmitted 7/6/2015 12:35:54 PM Accepted 7/7/2015 3:20:41 PM ABEL ACOSTA July 7, 2015 NO. CLERK ABELACOSTA, CLERK IN THE RT OF CRIMINAL APPEALS OF TEXAS ANTHONY CARL CRAVER Petitioner v. THE STATE OF TEXAS Respondent Petition is in Cause No. 1272901D from Criminal District Court No. Two of Tarrant County, Texas, and Cause No. 02-14-00076-CR in the Court of Appeals for the Second District of Texas MOTION TO FILE ENLARGED PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF CRIMINAL APPEALS: COMES NOW, Anthony Carl Craver ("Petitioner"), who files his Motion to File Enlarged Petition for Discretionary Review pursuant to Rule 9.4(i)(4) of the Texas Rules of Appellate Procedure, and in support would respectfully show unto this honorable Court the following: Craver v. State - Motion to File Enlarged Petition for Discretionary Review Page 1 of 3 Petitioner has submitted concurrent with this Motion his Petition for Discretionary Review. Exclusive of the pages containing the caption, identity of parties and counsel, statement regarding oral argument, table of contents, index of authorities, statement of the case, statement of issues presented, statement of jurisdiction, statement of procedural history, signature, proof of service, certification, certificate of compliance, and appendix, the Petition contains 5621 words, or 1,121 words over the page limit set forth in Rule 9.4(i)(2)(E) of the Texas Rules of Appellate Procedure. See TEX. R. APP. P. 9.4(i)(2)(E). The additional 1,121 words are necessary and should be allowed by this Court for the following reasons: 1) the complexity of the legal and factual issues raised by the circumstances of this case; and 2) were counsel required to omit 1,121 words of argument and analysis from the instant Petition, the effectiveness of his representation might be severely impacted and would interfere with the orderly administration of justice. PREMISES CONSIDERED, Petitioner Anthony Carl Craver prays that this Court grant this Motion in all respects, and allows him to file his Enlarged Petition submitted concurrently with this Motion. Petitioner prays for any further relief to Craver v. State - Motion to File Enlarged Petitionfor Discretionary Review Page 2 of 3 which he may be justly entitled. Respectfully submitted, /s/Abe Factor Abe Factor TBN: 06768500 Factor, Campbell & Collins Attorneys at Law 5719 Airport Freeway Fort Worth, Texas 76117 Phone: (817) 222-3333 Fax: (817) 222-3330 Email: lawfactor@yahoo.com Attorneys for Petitioner Anthony Carl Craver CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been furnished to counsel for the State's Prosecuting Attorney and the Tarrant County DistrictAttorney by a manner compliantwith the Texas Rules of Appellate Procedure, on this 6th day of Tuly_, 2015. /s/Abe Factor Abe Factor Craver v. State - Motion to File Enlarged Petition for Discretionary Review Page 3 of 3