Rodriguez, Pedro Jr. ( 2015 )

PD-0986-15 PD-0986-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/31/2015 12:34:00 PM July 31, 2015 Accepted 7/31/2015 3:14:51 PM ABEL ACOSTA No. ___________ CLERK In the COURT OF CRIMINAL APPEALS ______________________________________ On Appeal from the 272nd Judicial District Court of Brazos County, Texas Cause Number 09-03781-CRF-272; and the Opinion of the Tenth Court of Appeals in Cause Number 10-14-00227-CR, Delivered July 31, 2015 ______________________________________ PEDRO RODRIGUEZ, JR. v. THE STATE OF TEXAS _____________________________________ MOTION FOR EXTENSION OF TIME TO FILE PRO SE PETITION FOR DISCRETIONARY REVIEW ______________________________ TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: COMES NOW, Kristen Jernigan, the undersigned attorney of record for Pedro Rodriguez, Jr., the Appellant, herein, and files this Motion for Extension of Time to File Pro Se Petition for Discretionary Review. As set out below, the undersigned respectfully requests a sixty-day extension so that Appellant can file his Pro Se Petition for Discretionary Review. In support of said motion, the undersigned would show the Court the following: 1. Appellant’s Petition for Discretionary Review is currently due in this case on August 29, 2015. 2. Appellant seeks an extension of sixty days in which to file his Petition for Discretionary Review, making his Petition due on or before October 29, 2015. 3. The undersigned counsel will not be representing Appellant after the filing of this motion. Appellant will now have to obtain and review the record in order to prepare and file a Pro Se Petition for Discretionary Review. The undersigned believes that there is insufficient time between now and August 29, 2015, to accomplish those goals. Consequently, the undersigned respectfully requests that the Court grant Appellant the additional time. 4. The undersigned has not filed any previous motions for extension of time in this case. 5. For the reasons set forth above, the undersigned respectfully requests that Appellant be granted an extension of sixty days so that his petition for discretionary review in this case will now be due on October 29, 2015. PRAYER WHEREFORE, PREMISES CONSIDERED, the undersigned respectfully requests that this Court grant this Motion for Extension of Time to File Pro Se Petition for Discretionary Review. Respectfully submitted, _______/s/__Kristen Jernigan______ KRISTEN JERNIGAN State Bar Number 90001898 207 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 931-3650 (fax) Kristen@txcrimapp.com CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Appellant’s Motion for Extension of Time has been emailed to Doug Howell, Attorney of the Record for the Brazos County District Attorney’s Office on July 31, 2015. __/s/ Kristen Jernigan__________________ Kristen Jernigan 2