Christmas, Lemarcus Ashontay

Opinion

PD-0544&0545&0546-15

PD-0544&0545&0546-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 5/7/2015 3:42:49 PM Accepted 5/8/2015 10:46:44 AM NO. __________________________ ABEL ACOSTA CLERK

LEMARCUS ASHONTAY § IN THE COURT OF CHRISTMAS § §

VS. § CRIMINAL APPEALS §

STATE OF TEXAS § OF TEXAS

MOTION TO EXTEND TIME TO

FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

Now comes LEMARCUS ASHONTAY CHRISTMAS, Appellant in the above styled and numbered cause, and moves for an extension of time of 30 days to file a petition for discretionary review, and for good cause shows the following:

1. On April 14, 2015, the Court of Appeals for the Fourteenth Judicial District at Houston affirmed appellant's conviction in the matter of LEMARCUS ASHONTAY CHRISTMAS v. State, under case numbers 14-13-01102-CR, 14-13-01103-CR, 14-13-01104-CR. This petition is therefore due on MAY 14, 2015.

2. Counsel has been unable to complete the petition for the following reasons:

Counsel has recently returned from maternity leave.

3. Defendant is currently incarcerated.

4. No extensions of time to file Petition for Discretionary Review have been granted.

5. No motions for rehearing or en banc considerations have been filed.

WHEREFORE, PREMISES CONSIDERED, appellant respectfully requests an extension of 30 days, i.e. until June 14, 2015, to file a petition for discretionary review.

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May 8, 2015

Respectfully submitted,

Law Office of Jessica Marie Jaramillo Moreno 2512 1st Street

Rosenberg, Texas 77471

Tel: 281-658-1336

Fax: 281-667-3023

jmjm.esq@gmail.com

By:

Jessica Jaramillo-Moreno

State Bar No. 24078733

Attorney for LEMARCUS ASHONTAY CHRISTMAS

CERTIFICATE OF SERVICE

This is to certify that on May 07, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Fort Bend County, Texas, by facsimile transmission to 281-341-4440.

Jessica Jaramillo-Moreno

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