Reyes, Colette

PD-1627-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
December 18, 2015 Transmitted 12/16/2015 3:12:59 PM
Accepted 12/18/2015 1:51:27 PM
ABEL ACOSTA
CLERK
IN THE COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
COLETTE REYES §
APPELLANT §
§
VS. § NO. ____________________
§
THE STATE OF TEXAS §
APPELLEE §
APPELLANT’S MOTION FOR EXTENSTION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF THE TEXAS COURT OF CRIMINAL APPEALS:
COMES NOW COLETTE REYES hereinafter referred to as Appellant, by and through
her attorney of record, WES BALL and files this her MOTION FOR EXTENSTION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW, pursuant to Texas Rule of Appellate
Procedure 68.2, and in support thereof would show the Court as follows:
I.
Appellant was convicted of the offense of Murder and was sentenced to forty-five (45)
years confinement in the Institutional Division of the Texas Department of Criminal Justice and
at this time is incarcerated. Following her conviction, Appellant appealed to the Second Court of
Appeals, sitting in Fort Worth, Texas.
On November 12, 2015 the Second Court of Appeals issued its decision affirming
Appellant’s conviction and sentence in Colette Reyes v. The State of Texas, No. 02-13-00563-CR
(Tex. App. – Fort Worth).
Motion for Extension of Time to File
Petition for Discretionary Review Page 1 of 3
On November 19, 2015, Appellant filed a Motion for Rehearing, and on November 25,
2015 the Motion for Rehearing was denied by the Second Court of Appeals. It is Appellant’s
desire to Petition this Honorable Court for review of her case in a Petition for Discretionary
Review.
Appellant’s undersigned counsel has just assumed responsibility for the filing of the
Petition for Discretionary review and is unable to file the Petition for Discretionary Review by
the current due date. Appellant’s Petition is due on December 24, 2015. Appellant is confident
that her petition will be completed and filed on or before January 23, 2016. This would only
consist of a delay from the previous due date of thirty (30) days. There have been no previous
extensions sought or granted for this filing.
WHEREFORE, PREMISES CONSIDERED, APPELLANT prays that this Honorable
Court enter an order granting this request for an extension of time to file her Petition for
Discretionary Review until January 23, 2016.
Respectfully submitted,
/s/ Wes Ball
WES BALL
State Bar No: 01643100
4025 Woodland Park Blvd., Suite 100
Arlington, Texas 76013
Email: WBnotices@ballhase.com
Tel: (817) 860-5000
Fax: (817) 860-6645
ATTORNEY FOR APPELLANT
Motion for Extension of Time to File
Petition for Discretionary Review Page 2 of 3
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion for
Extension of Time to file Petition for Discretionary Review was delivered by Efile portal to the
Post-Conviction Division of the Tarrant County District Attorney=s Office, Fort Worth, Texas
and the State Prosecuting Attorney, Austin, Travis County, Texas on this the 16th day of
December, 2015.
/s/ Wes Ball
WES BALL
Attorney for Defendant
CERTIFICATE OF CONFERENCE
On the 16th day of December, 2015, Malinda Davis, Assistant to Appellant=s counsel
contacted Assistant District Attorney, Debra Windsor, with the Post-Conviction Division of the
Tarrant County District Attorney=s Office regarding the foregoing Motion and has been advised
that the state does not oppose the Motion.
/s/ Wes Ball_______________________________
WES BALL
Motion for Extension of Time to File
Petition for Discretionary Review Page 3 of 3