Buchanan, Raymond Jr.

• Court: Court of Appeals of Texas
• Decided: January 21, 2015
• Docket: PD-0063-15
• Status: Published

Opinion

PD-0063-15 PD-0063-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 1/15/2015 10:28:43 PM Accepted 1/21/2015 3:44:09 PM TO THE COURT OF CRIMINAL APPEALS OF TEXAS ABEL ACOSTA CLERK

No.____________

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RAYMOND BUCHANAN, Appellant v. THE STATE OF TEXAS, Appellee

MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

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On Petition for Discretionary Review from the Court of Appeals for the First District, Houston, Texas in Cause No. 01-13-00954-CR, Affirming an appeal from a judgment issued in Cause No. 68872 from the 300th District Court of Brazoria County, Texas.

R. Scott Shearer TBA No. 00786464 929 Preston, Suite 200 Houston, TX 77002 January 21, 2015 (713) 254-5629 (713) 224-2889 FAX ShearerLegal@Yahoo.com

Attorney for Appellant

January 15, 2014 TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS:

NOW COMES, RAYMOND BUCHANAN, and files this Motion To Extend

Time To File Petition For Discretionary Review. In support of this motion, he would

respectfully show the Court the following:

I.

In an UNPUBLISHED opinion delivered December 16, 2014, a panel of the First

Court of Appeals AFFIRMED Appellant’s appeal from a judgment of conviction for sexual

abuse of a child by the 300th District Court of Brazoria County. Appellant did not file a

motion for rehearing. Appellant’s Petition for Discretionary Review is due on January 16,

2014. This motion to extend time to file petition for discretionary review is timely filed

within thirty days after the court of appeals issued its opinion or overruled Appellant’s

Motion for Rehearing or within fifteen days of said deadline. See TEX. R. APP. PROC. 68.2.

II.

Appellant is requesting additional time to file the petition for discretionary review.

More time is necessary to research the issues involved.

III.

Appellant asserts that this motion is not made solely for purposes of delay and that

the granting of this motion will not prejudice the rights of the State. IV.

Appellant is therefore requesting a thirty [30] day extension so that his Petition may

be timely filed.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the

Honorable Court of Criminal Appeals will grant his Motion To Extend Time To File

Petition For Discretionary Review.

Respectfully submitted,

/s/R. SCOTT SHEARER R. Scott Shearer TBA No. 00786464 929 Preston, Suite 200 Houston, TX 77002 (713) 254-5629 (713) 224-2889 FAX ShearerLegal@Yahoo.com

January 15, 2014 CERTIFICATE OF SERVICE

I certify that a copy of this Motion has been served upon the State of Texas by e- mailing a copy of same to the following parties at the following addresses on this the 15th day of January, 2014:

JERI YENNE. BRAZORIA COUNTY DISTRICT ATTORNEY 111 E. LOCUST, SUITE 408A ANGLETON, TX 77515 DEBRAP@BRAZORIA-COUNTY.COM

/s/R. SCOTT SHEARER R. Scott Shearer