Barragan, Rolando

• Court: Court of Appeals of Texas
• Decided: June 2, 2016
• Docket: PD-0443-16
• Status: Published

Opinion

PD-0443-16 PD-0443-16 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS June 2, 2016 Transmitted 6/2/2016 2:25:17 PM Accepted 6/2/2016 4:13:56 PM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK FOR THE STATE OF TEXAS

ROLANDO BARRAGAN * Appellant * * COA# vs. * No. 10-15-00079-CR * THE STATE OF TEXAS * Appellee

MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE COURT OF APPEALS:

COMES NOW, the Appellant, by and through her undersigned Attorney of

Record, and respectfully moves the Court to extend the time for filing a petition for

discretionary review in this cause, and in support therefore would show the Court as

follows:

I.

That Appellant was found guilty of the offense of Indecency of a Child, No.2011-

1161-C1 in the 19th District Court of McLennan County, Texas. Appellant was

sentenced by the court and timely gave notice of Appeal.

II.

Appellant’s petition for discretionary review is currently due on June 1, 2016.

III.

Appellant hereby requests an extension of time to file his Petition for Discretionary

Review until June 2, 2016, and as reasons therefore would show this cause as follows: Counsel was unable to complete the petition for discretionary review by the current

due date.. Counsel has had a medical issue that has required a substantial amount of time

to resolve over the last several days. The petition was almost done, but counsel had to be

out of the office on June 1, and was unable to get it submitted. The petition is being

submitted with this motion.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests this

honorable court to extend the time for filing Appellant's Petition for Discretionary Review

in this cause to June 2, 2016.

Respectfully submitted,

/s/ Walter M. Reaves, Jr. Walter M. Reaves, Jr. 100 N. 6 th Street, Suite 802 Waco, Texas 76701 (254) 296-0020 FAX (877) 726-4411 TBA#16644200 walterreaves@att.net

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing motion was delivered

to Abel Reyna, District Attorney for McLennan County, Texas, on June 2, 2016.

/s/ Walter M. Reaves, Jr. Walter M. Reaves, Jr.