Smith, Jacob Brent ( 2015 )

PD-1599-15 PD-1599-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/9/2015 9:43:46 AM
Accepted 12/11/2015 10:37:40 AM
ABEL ACOSTA
PD No: - - - - - - CLERK
JACOB BRENT SMITH IN THE TEXAS COURT
vs. OF CRIMINAL APPEALS
STATE OF TEXAS AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT'S PRO-SE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, Appellant, by and through the undersigned attorney, who has
personal knowledge of the matters contained herein, and files this Motion for Extension of
Time to File Appellant's Pro-Se Petition for Discretionary Review, and in support thereof
would show:
I.
Appellant was convicted of evading arrest or detention in a vehicle and sentenced to
30 years in the Texas Department of Criminal Justice - Institutional. The trial court was
the 185th District Court of Harris County, Texas. The trial court cause number was:
1410410. On December 1, 2015, the Fourteenth Court of Appeals in Houston, Texas,
affirmed appellant's conviction in appellate cause number: 14-14-00681-CR.
II.
The current deadline for filing appellant's Petition for Discretionary Review is
December 31, 2015.
December 11, 2015
III.
No previous extension of time to file a Petition for Discretionary Review has been
requested by appellant.
IV.
The undersigned is not pursuing further appellate review on behalf of Mr. Smith. The
undersigned is notifying appellant of his right to pursue a Petition for Discretionary Review
in this Court.
v.
Appellant is requesting an additional thirty (30) day extension until February 1, 2016
in which to file his pro-se 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.
VII.
Appellant's last known address within the Texas Department of Criminal Justice is:
Mr. Jacob Brent Smith
TDCJ-ID # 1947387
Eastham Unit
2665 Prison Road 1
Lovelady, Texas 75851
WHEREFORE, PREMISES CONSIDERED, the undersigned prays that the Court
grant this Motion for Extension of Time to File Appellant's Pro-Se Petition for
Discretionary Review until February 1, 2016.
Respectfully submitted,
w~
SBOT: 09656300
4615 Southwest Freeway, Suite 600
Houston, Texas 77027
(713) 623-8312
wthlaw@aol.com
CERTIFICATE OF SERVICE
A true and correct copy of this motion was mailed to:
Harris County District Attorney's Office
Appellate Division
1201 Franklin, 61h Floor
Houston, Texas 77002
Mr. Jacob Smith
(Address noted above)