Acosta, Steve

Opinion

PD-1080-15

PD-1080-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 8/18/2015 11:15:09 PM Accepted 8/20/2015 11:52:27 AM ABEL ACOSTA

CLERK

NO. _______________

IN THE COURT OF CRIMINAL APPEALS

STEVE ACOSTA

August 20, 2015 Appellant, vs.

THE STATE OF TEXAS,

Appellee

On Appeal from the 5th District Court of Appeals Dallas, Texas

APPELLANT’S MOTION FOR EXTENSTION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

Comes Now, STEVE ACOSTA, Appellant/Petitioner who hereby files this First Motion for Extension of Time to File Petition for Discretionary Review under Tex. R. App. P. 68.2. In support of this motion, per Tex. R. App. P.

10.5, Petitioner shows the following:

1. The Court of Appeals for the 5th Appellate District in Dallas, TX, rendered its opinion and judgment in Steve Acosta v. State of Texas,

2

Trial Court Cause No. F-1355987-M, Appellate Cause No. 05-13-01640-CR on July 7, 2015. The Petition for Discretionary Review is due no later than August 6, 2015. Counsel requests this extension prior to 15 days from August 6, 2015.

2. Petitioner requests an extension of time of thirty days, to September 7, 2015. This is Petitioner’s first request for an extension of time in this case.

3. Petitioner relies on the following facts as a reasonable explanation for the requested extension of time: Counsel is involved in numerous Federal and State appeals and trials involving complex issues and extensive transcripts. Counsel must review 1200 pages of transcripts in one appeal and 4 terabytes of information on a trial matter. Both are set in the next month.

WHEREFORE PREMISES CONSIDERED, Petitioner prays that this Court grant this Motion for Extension of Time.

Respectfully submitted,

/s/ Bruce Kaye

Bruce Kaye

TBN 00784374

2309 Boll St.

Dallas, TX 75204

(214) 722-7438 Office

(866) 649-8757 Fax

Bruce@Brucekaye.com