Carrasco, Tony ( 2015 )

PD-1425-15
PD-1425-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
November 5, 2015 Transmitted 11/5/2015 12:12:46 PM
Accepted 11/5/2015 3:18:43 PM
No. 07-14-00001-CR ABEL ACOSTA
CLERK
TONY CARRASCO § IN THE COURT OF APPEALS
§
V. § OF THE SEVENTH SUPREME
§
STATE OF TEXAS § JUDICIAL DISTRICT
MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW the Appellant, by and through his counsel, David Crook, and files
this motion for an extension of 30 days or the maximum amount of time possible in
which to file his Petition for Discretionary Review in the above-referenced appeal. In
support of this motion, Appellant would show the Court the following:
I.
On October 20, 2015, the Seventh Court of Appeals, in Appellate No. 07-14-
00001-CR, styled Tony Carrasco v. the State of Texas, affirmed the judgment of the
Court below.
II.
The present deadline for filing Appellant’s Petition for Discretionary Review is
November 9, 2015. The Appellant has not requested any extensions with regard to his
P.D.R. prior to this request.
III.
Appellant's request for an extension is based upon the following facts: Counsel
has had a recent need for a medical trip for several days to Houston, TX at M.D.
Anderson center.
Prayer
WHEREFORE, appellant prays that the Court grant this motion and extend the
deadline for filing the Appellant’s Petition for Discretionary Review in Appellate No. 07-
14-00001-CR to Wednesday, December 9, 2015.
Respectfully submitted,
Crook & Jordan
By: /s/David Crook
David M. Crook
PO Box 94590
Lubbock, TX 79493
(806) 744-2082
SBN: 05109530
Telephone: (806) 744-2082
Fax: (806) 744-2083
dcrook@nts-online.net
Attorney for Appellant
CERTIFICATE OF SERVICE
This is to certify that a copy of the above-entitled and numbered motion has been
served on Jeff Ford, attorney for the state, by e-mail, on this the 5th day of November,
2015.
/s/David Crook
DAVID CROOK
Appellant’s M.Xtn.PDR 2