McNeill, Douglas Eugene ( 2015 )

PD-1015-15
PD-1015-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/6/2015 5:24:29 PM
August 11, 2015 Accepted 8/11/2015 11:54:04 AM
CAUSE NO. _____________ ABEL ACOSTA
CLERK
DOUGLAS E. MCNEILL § IN THE COURT OF
§
V. § CRIMINAL APPEALS
§
STATE OF TEXAS § OF TEXAS
MOTION TO EXTEND TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
Now comes Douglas E. McNeill, Appellant in the above styled and numbered cause, and
moves for an extension of time of thirty days to file a brief in support of Petition for
Discretionary Review, and for good cause shows the following:
1. On June 30, 2015, the Court of Appeals affirmed appellant’s conviction, Douglas
Eugene McNeill V. The State of Texas, #12-14-00145-CR. This petition was therefore due on
July 30, 2015. This motion is filed pursuant to Rule of Appellate Procedure 68.2C.
2. Counsel has been unable to complete the brief for the following reasons:
a. Counsel is a sole practitioner, and received the judgment from the Court of
Appeals a few days after returning from a law seminar in San Antonio, and was
catching up time out of the office as a result.
b. Since receiving the Tyler Court’s judgment, the undersigned has been
involved in several different contested family law matters, including divorces and
CPS cases, heard contested motion to suppress in a DWI case, conducted an
appeal of a driver license suspension, and tried another DWI case to a jury.
c. Counsel spent approximately one full week taking his wife to multiple
doctor appointments, including an emergency room visit and two doctor office
visits in Palestine, a trip to Tyler for a MRI exam, and then an additional trip to
Tyler to confer with a back specialist.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully requests an
extension of thirty days, i.e., until September 6, 2015, to file a Petition for Discretionary Review.
Respectfully submitted,
Wm. M. House, Jr., P.C.,
Attorney for Douglas E. McNeill
By: /S/ Wm. M. House, Jr.
Wm. M. House, Jr.
Texas Bar No. 10045000
Email: wmmhousejr@embarqmail.com
800 N Church
Palestine TX 75801
Tel: 903-723-2077
Fax: 903-723-6323
Certificate of Service
This is to certify that on August 6, 2015 a true and correct copy of the above and
foregoing document was served on the District Attorney’s office, Anderson County, Texas via
internet website https://efile.txcourts.gov.
Wm. M. House, Jr., P.C.,
Attorney for Douglas E. McNeill, Appellant