Escobar, Tony ( 2015 )

PD-1498-15
PD-1498-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/17/2015 5:46:55 PM
November 18, 2015
Accepted 11/18/2015 3:05:49 PM
ABEL ACOSTA
PD No:- - - - - - CLERK
TONY ESCOBAR IN THE TEXAS COURT
vs. OF CRIMINAL APPEALS
STATE OF TEXAS AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT'S PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, Appellant, Tony Escobar, by and through the undersigned attorney,
and files this Motion for Extension of Time to File Appellant's Petition for Discretionary
Review, and in support thereof would show:
I.
Appellant was convicted of capital murder and sentenced to life in the Texas
Department of Criminal Justice - Institutional Division. The trial court was the 33gth District
Court of Harris County, Texas. The trial court cause number was 1344348. On October 29,
2015, the First Court of Appeals in Houston, Texas, affirmed appellant's conviction in
appellate cause number 01-14-00593-CR.
II.
The current deadline for filing appellant's petition for discretionary review is
November 30, 2015.
III.
No previous extension of time to file a petition for discretionary review has been
requested by appellant.
IV.
The undersigned visited Appellant at the Connally Unit in Kenedy, Texas, to discuss
the Opinion issued by the First Court of Appeals. Additional time is needed for the
undersigned to evaluate the potential issues to be presented to this Court on petition for
discretionary review. The undersigned is also requesting this extension due to trial and
appellate scheduling conflicts which prevent him from completing a petition for
discretionary review by the current due date.
v.
Appellant is requesting an extension until December 28, 2015 in which to file a
petition for discretionary review in this matter
VI.
This request is not made for the purpose of delay but to insure Appellant's right to
appellate review in this matter.
WHEREFORE, PREMISES CONSIDERED, the undersigned prays that the Court will
grant this Motion for Extension of Time to File Appellant's Petition for Discretionary Review
until December 28, 2015.
Respectfully submitted,
w~
SBOT: 09656300
4615 Southwest Freeway, Suite 600
Houston, Texas 77027
Tel: (713) 623-8312
Fax: (713) 626-0182
email: wthlaw@aol.com
BEFORE ME, the undersigned authority, on this day personally appeared Wayne T.
Hill, who after being duly sworn by me, upon his oath did state that the information )
contained in the above \MQfMm for extension of ime is true and c rrect. ( 1I - I - 2 o / 5
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A true and correct copy of this motion will be delivered to:
Harris County District Attorney' s Office
Appellate Division
1201 Franklin, 61h Floor
Houston, Texas 77002