Flores, Edward ( 2015 )

PD-0349-15
PD-0349-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
March 31, 2015 Transmitted 3/30/2015 3:05:38 PM
Accepted 3/31/2015 2:53:09 PM
Court of Criminal Appeals No. _______________ ABEL ACOSTA
CLERK
Appeal No. 01-13-00295-CR
Trial Cause No. 12-08-08659-CR
EDWARD FLORES § IN THE COURT OF CRIMINAL
§
VS. § APPEALS
§
STATE OF TEXAS § AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, Edward Flores, Appellant, and requests this Court grant an
extension of time to file his Petition for discretionary review and would show unto the
Court the following:
1. On February 26, 2015, the Court of Appeals delivered and filed its opinion
in Appeal No. 01-13-00295-CR, styled Edward Flores v. State of Texas, in the First
Court of Appeals in Houston, Texas.
2. The deadline for filing a petition for discretionary review is March 30,
2015.1. The Deadline for filing a motion for extension of deadline to file Petition for
Discretionary review pursuant to Texas Rule of Appellant Procedure 68.2(c) is April 15,
2015.
3. Appellant is requesting an extension of at least sixty days.
4. Appellant's counsel is requesting this extension of time to his motion to
file Appellant's Brief because Appellant's Counsel was set for Jury on March 2, 2015 on
an Aggravated Robbery, Aggravated Kidnapping and unadjudicated Aggravated
1
The actual due date to file the motion for rehearing is March 28, 2015. Since March 28, 2015 is a
Saturday, the due date would be moved to the first business day, which would be March 30, 2015. T.R.A.P
4.1(a)
robberies and assault on public servant’s in the 411th Judicial District Court of Polk
County. That Polk County case plead only the Friday before jury selection was to start.
Counsel was also in Jury trial the week of March 9, 2015 in a Habitual first degree
delivery of a controlled substance in the 75th Judicial District Court of Liberty County,
Texas. Finally, Appellant Counsel is beginning jury trial, March 30, 2015 in the 258th
Judicial District Court of Polk County, on an Aggravated robbery case that has 16 media
disks, over 6000 pages in medical records, and over 500 pages in police and Texas Ranger
reports.
5. No other extensions for time to file an extension to file Petition of
Discretionary Review have been previously granted to this attorney in this appeal.
Respectfully Submitted,
_______________________________
Scott Pawgan
State Bar No. 24002739
122 W. Davis, Ste 116
Conroe, Texas 77301
Phone (936) 242-6975
Fax (800) 619-5113
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing was served upon the attorney
for the State via the electronic service feature of the e-file provider this motion was filed
with on the March 30, 2015.
___________________________________
Scott Pawgan
Court of Criminal Appeals No. _______________
Appeal No. 01-13-00295-CR
Trial Cause No. 20795
EDWARD FLORES § IN THE COURT OF CRIMINAL
§
VS. § APPEALS
§
STATE OF TEXAS § AUSTIN, TEXAS
ORDER ON MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
On this day came to be heard Appellant’s Motion For Extension Of Time To File
Petition For Discretionary Review and the Court is of the opinion the motion should be
GRANTED.
IT IS ORDERED that Appellant’s deadline to file Appellant’s Petition for
Discretionary review be extended from April 8, 2011 and Appellant’s Petition for
Discretionary Review is now due _____________________.
____________________________
Judge, Court of Criminal Appeals