Amilpas, Jose ( 2015 )

PD-0614-15
PCCI
ceived m
IN THE COURT OF CRIMINAL APPEALS ™MMAl APPEALS
OF THE STATE OF TEXAS
NO. ot-q-00o<*~aa f^ 22 2015
•"«»Acosia, Clerk
JOSE AMILPAS
Appellant,
On Appeal from the
V. 174™ District Court of
Harris County, Texas;
Trial Cause Number 1334791
THE STATE OF TEXAS
PETITIONER'S MOTION TO EXTEND TIME TO FILE FILED IN
PETITION FOR DISCRETIONARY REVIEV^QURT OF CRIMINAL APPEALS
MAY 2 2 2015
TO THE HONORABLE JUSTICES OF SAID COURT:
Abe|Acosta, Clerk
JOSE AMIPLAS, Petitioner in the above cause number, would respectfully
request the Court to grant his motion to extend the time to file his petition for
discretionary review. In support of said motion, Appellant would show unto the
Court the following:
I.
This appeal lies from Appellant's convictions in The State of Texas 'v. Jose
Amilpas, No. 01-14-00053rCR; Cause Number 1334791 in the 174th District Criminal
Court of Harris County, Texas. Mr. Amilpas was charged with felony possession of
more than four grams and less than 200 grams of cocaine with intent to deliver. Mr.
Amilpas pleaded not guilty to the offense and after a jury found him guilty as charged
the trial court assessed punishment at thirty (30) years in the Institutional Division of
the Texas Department of Criminal Justice pursuant to an agreed recommendation by
the State. Appellant's Petition for Discretionary Review is due May 25, 2015. This is
Appellant's first request for an extension to file the petition for discretionary review.
II.
Appellant is requesting an extension of time in order to fully evaluate the issues
to be raised in the PDR. An extension of time is necessary so that the petition for
discretionary review can be timely filed. This motion is not made for the purpose of
delay.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this
Honorable Court will grant this requested extension of time to file the Appellant's
Petition for Discretionary Review in the above cause for ninety days and extend the
time for filing the petition until July 24, 2015.
Respectfully submitted,
!4i=-
Mr. Jose Amilpa^
TDCJ No. 01908295
French Robertson Unit
12071 FM 3522
Abilene, Texas 79601
CERTIFICATE OF SERVICE
I do hereby certify that a copy of the foregoing instrument was this day&2rved
on counsel for the State by mailing same to the following parties on this theffifflay of
Mr. Allen Curry
Harris County District Attorney's Office
Appellate Division
1201 Franklin, Suite 600
Houston, Texas 77002
State Prosecuting Attorney
P.O. Box 12405
Austin, Texas 78711
c
L6se Amilpas, PRO SE