Flores, Adan ( 2015 )

PD-1414-15 PD-1414-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS November 3, 2015 Transmitted 11/2/2015 1:28:16 PM Accepted 11/3/2015 1:32:57 PM ABEL ACOSTA CAUSE NO. _ _ _ _ _ __ CLERK IN THE TEXAS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS ADANFLORES, Appellant Court of Appeals No. 04-14-0091S-CR Trial Court No. 2014CRS000311-Dl V. THE STATE OF TEXAS, 49th District Court of Appellee Webb County, Texas APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE A PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE TEXAS COURT OF CRIMINAL APPEALS: Comes now Appellant, ADAN FLORES, asking the Court for a IS-day extension to file his petition for a discretionary review and for good cause shows: 1. ADAN FLORES was convicted of five counts of aggravated assault of a child and one count indecency with a child by contact. He is appealing as an indigent. 2. The conviction was affirmed on September 30, 2015, in a memorandum opinion rendered by the Fourth Court of Appeals. 3. FLORES desires to petition for a discretionary review of his conviction and asks that the time to file his petition be extended until November Page 11 14,2015. 4. FLORES is represented by the undersigned court-appointed attorney ARMANDO TREVINO. 5. TREVINO represents the mother of one of six persons killed in a four-vehicle accident in Dimmit County, Texas. There are more than thirty plaintiffs and numerous attorneys in this case. Discovery is extensive, ongoing, and includes many depositions, all of which require the time of Armando Trevino, Appellant's counsel. In addition, Appellant's counsel has criminal and civil cases in South Central Texas that require his attention. 6. This motion is not made for purpose of delay but is made so that justice may be done. 7. PRAYER. Premises Considered, Appellant ADAN FLORES asks that the Court grant his motion for extension of time to file his petition for discretionary review. Respectfully submitted, /s/ Armando Trevino ARMANDO TREVINO State Bar No. 20211100 1519 Washington St., Suite One Laredo, Texas 78040 Tel: (956) 726-1638 Email: armando_trevinolaw@hotmail.com Attorney for Appellant ,-rt / Subscribed and sworn to on the ,t day of November, 2015. No~ry Public, State of Texas Page 12 CERTIFICATE OF SERVICE A true copy of the above document was served on the 2 nd day of November 2015, on Keith E. Hottle, Clerk of the Fourth Court of Appeals, Cadena-Reeves Justice Center, Suite 3200, San Antonio, Texas 78205; and on David L. Reuthinger, Jr., Assistant District Attorney of Webb County, 1110 Victoria Street, Suite 401, Laredo, Texas 78045. lsi Armando Trevino ARMANDO TREVINO Page 13