Washington, Glynn Chase ( 2015 )

PD-0717-15
PD-0717-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
June 12, 2015 Transmitted 6/12/2015 9:37:29 AM
Accepted 6/12/2015 12:52:20 PM
ABEL ACOSTA
PDR No. __________
CLERK
IN THE COURT OF CRIMINAL APPEALS
14-13-00678-CR
IN THE COURT OF APPEALS FOR THE
FOURTEENTH DISTRICT OF TEXAS AT HOUSTON
No. 12-DCR-059441A & 12-DCR-059442
in the 240th Judicial District
Fort Bend County, Texas
MOTION FOR EXTENSION OF TIME TO FILE PDR
COMES NOW, The Petitioner by and through his undersigned counsel and for good cause
shown hereby requests an extension of 30 days to file the Pro Se Petition for Discretionary
Review. In support thereof he would show this Honorable Court the following:
1. The Court of Appeals’ judgement is dated March 17th, 2015.
2. Motion for en banc reconsideration was filed on April 1st, and denied on April 28th,
2015 by the Fourteenth Court of Appeals.
3. The Petitioner was notified of his right to file a pro se PDR via certified mail but to
this date counsel has no indication from his client as to whether he wishes to take
advantage of his pro se appellate right.
4. If the client was moved or due to some delay in the mail beyond his control was not
able to receive the certified mailing in a timely manner then it would serve the
interest of justice to extend the time for him to file the PDR with the Court of
Appeals.
5. Since the petitioner would be a pro se litigant, liberal relaxation of the timelines
within the Rules of Appellate Procedure, would serve the interest of justice,
considering his incarceration.
FOR THESE REASONS, pursuant to TRAP 4.5 (a) and 68.2 (c) which permits extension of
time to file the PDR in this court for good cause, the Petitioner respectfully request that this
Honorable Court grant a 30 day extension in order to file a pro se PDR in the Court of
Criminal Appeals.
Respectfully submitted,
Patrick F. McCann
Patrick F. McCann
SBN# 00792680
909 Texas Ave, Ste. 205
Houston, Texas 77002
PH: 713.223.3805
eFAX: 281.667.3352
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion was
delivered to all counsel of record on the 12th day of June, 2015.
Patrick F. McCann
Patrick F. McCann
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion was
delivered to the pro se party at last known address on the 12th day of June, 2015.
Patrick F. McCann
Patrick F. McCann