Bowman, Keith Wylie

• Court: Court of Appeals of Texas
• Decided: March 25, 2015
• Docket: PD-0310-15
• Status: Published

Opinion

PD-0309-15, PD-0310-15 & PD-0311-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/20/2015 4:58:07 PM Accepted 3/25/2015 9:44:50 AM ABEL ACOSTA No. ______________________ CLERK

IN THE COURT OF CRIMINAL APPEALS OF TEXAS

KEITH WYLIE BOWMAN, Petitioner–Appellant

v.

THE STATE OF TEXAS, Respondent–Appellee

Petition for Discretionary Review from the Fifth District Court of Appeals at Dallas Cause Nos. 05-13-01741-CR, 05-13-01742-CR, and 05-13-01743-CR

Appeal from of Dallas County, Texas Cause Nos. F10-35883-W, F10-35927-W, and F10-35928-W

MOTION FOR EXTENSION OF TIME TO FILE A PETITION FOR DISCRETIONARY REVIEW

Keith Wylie Bowman, Appellant below, respectfully submits this Motion

for an Extension of Time to File a Petition for Discretionary Review in the above–

styled and numbered cause. In support of this Motion, he shows this Honorable

Court the following:

March 25, 2015 I.

Appellant was convicted of three separate aggravated robbery charges. The

court sentenced him to 10 years’ imprisonment in one case and 20 years’

imprisonment in the other two cases.

II.

The Court of Appeals affirmed the trial court’s judgment in a memorandum

opinion and judgment filed on February 5, 2015. Bowman v. State, Nos. 05-13,

01741-CR, 05-13-01742-CR, and 05-13-01743-CR, 2015 Tex. App. LEXIS 1196

(Tex. App.—Dallas Feb. 5, 2015) (mem. op., not designated for publication).

Appellant filed a motion for rehearing in Appellate Cause No. 05-13-01742-CR,

which the Court of Appeals denied on March 9, 2015. Appellant’s petition for

discretionary review in that case is due April 8, 2015.

Appellant’s petition for discretionary review in Appellate Cause Nos. 05-13-

01741-CR and 05-13-01743-CR is due March 6, 2015. See TEX. R. APP. P.

68.2(a); see also TEX. R. APP. P. 4.1(a). Any motion for extension of time to file a

petition for discretionary review is due March 22, 2015. See TEX. R. APP. P.

68.2(c); TEX. R. APP. P. 4.1(a).

III.

The facts relied upon to show good cause for this requested extension are as

follows: 2 1. Appellant was represented by court appointed counsel during appeal of this case to the Court of Appeals.

2. It is undetermined at this time whether Appellant will proceed pro se for purposes of filing a Petition for Discretionary Review in one or more of these causes. Additional time is needed for consultation between appellate counsel and Appellant on this issue.

3. If Appellant proceeds pro se, then additional time will be needed to prepare and file the Petition pro se or to seek other legal assistance in filing the Petition.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully

requests that this Honorable Court extend the time for filing a Petition for

Discretionary Review for sixty days.

Respectfully submitted,

Lynn Richardson Chief Public Defender Dallas County

Katherine A. Drew Chief, Appellate Division Dallas County Public Defender’s Office

/s/ Julie Woods Julie Woods Assistant Public Defender Dallas County Public Defender’s Office State Bar Number: 24046173 133 N. Riverfront Blvd., LB 2 Dallas, Texas 75207 (214) 653-3550 (telephone) (214) 653-3539 (fax) Julie.Woods@dallascounty.org Attorneys for Petitioner 3 CERTIFICATE OF SERVICE

I certify that a true copy of the foregoing Motion for Extension of Time to File a Petition For Discretionary Review was served on Grace E. Shin, counsel for the State, Dallas County District Attorney’s Office, 133 N. Riverfront Blvd., LB- 19, 10th Floor, Dallas, Texas 75207, by eServe on March 20, 2015.

I further certify that a true copy of the foregoing Motion for Extension of Time to File a Petition For Discretionary Review was served on Lisa C. McMinn, the State’s Prosecuting Attorney, P.O. Box 13046, Capitol Station, Austin, Texas 78711, by eServe on March 20, 2015.

/s/ Julie Woods Julie Woods