Tumlinson, Charles Edward

PD-0121-15
PD-0121-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 2/2/2015 12:00:00 AM
Accepted 2/4/2015 10:32:25 AM
ABEL ACOSTA
NO. CLERK
IN THE COURT OF CRIMINAL APPEALS
OF TEXAS
CHARLES EDWARD TUMLINSON,
Appellant,
February 4, 2015
v.
THE STATE OF TEXAS,
Appellee.
From the First Court of Appeals
No. 01-14-00238-CR
Appealed from the 149th Judicial District Court
of Brazoria County, Texas
Trial Court Cause No. 50946
Honorable Terri Holder, Judge Presiding
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME
TO FILE A PETITION FOR DISCRETIONARY REVIEW
COMES Appellant, CHARLES EDWARD TUMLINSON, by and through
retained counsel, and in support of this motion would show as follows:
I.
On December 18, 2014, the First Court of Appeals rendered its Judgment
affirming Appellant’s conviction and sentence in Case Number 01-14-00238-CR
(Trial Court Cause No. 50946).
Appellant did not file a Motion for Rehearing or a Motion for En Banc
Reconsideraton.
II.
Appellant’s Petition for a Discretionary Review (“PDR”) was due on or before
January 17, 2015.
III.
Undersigned counsel was retained on January 30, 2015, to research, draft,
perfect and file Appellant’s PDR in this case.
IV.
Because the undersigned was retained only two (2) days ago, and because of
his rigorous court schedule, which includes two (2) trial settings on February 3, 2015,
in the 434th District Court of Fort Bend County, Texas, and two (2) trial settings on
February 9, 2015, in the 300th District Court of Brazoria County, Texas, Appellant is
seeking a fifteen (15) day extension of time, to and including February 17, 2015, in
which to file his PDR.
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V.
This is Appellant’s first motion for an extension of time to file his PDR.
WHEREFORE, Appellant prays that this motion be, in all things granted and
that this Court grant a fifteen (15) day extension of time to file his PDR, to and
including February 17, 2015.
Respectfully submitted,
LAW OFFICES OF D. CRAIG HUGHES
/s/ D. CRAIG HUGHES
D. CRAIG HUGHES
SBOT: 10211025
7322 Southwest Freeway, Suite 1100
Houston, Texas 77074
Tel - (713) 535-0683
Fax - (713) 981-3805
E-Mail: dcraighughes@msn.com
Attorney for Appellant
Charles Edward Tumlinson
CERTIFICATE OF SERVICE
I hereby certify that on February 1, 2015, a true and correct copy of the
foregoing Appellant’s First Motion for Extension of Time To File a Petition for
Discretionary Review was electronically filed and served on the Brazoria County
Criminal District Attorney’s Office.
/s/ D. CRAIG HUGHES
D. CRAIG HUGHES
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