Cochran, Mitchell Dean

Opinion

FILED IN PD-0793-15 COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 8/10/2015 7:24:12 PM August 11, 2015 Accepted 8/11/2015 4:41:59 PM ABEL ACOSTA

ABEL ACOSTA, CLERK PD 0793-15 CLERK

IN THE COURT OF CRIMINAL APPEALS 3r

\

MITCHELL DEAN COCHRAN

VS.

THE STATE OF TEXAS

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MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

I.

COMES NOW, Appellant in the above styled case, and makes and

files this his request for an extension of time to file his PDR and would show

unto the Court the following:

COURT BELOW: Tenth Court of Appeals

CAUSE NUMBER BELOW: NO. 10-14-00013-CR

DATE FOR PETITION OF DISCRETIONARY REVIEW REFUSED: None

PRESENT DEADLINE FOR FILING APPELLANTS' PDR: 8-10-15

Mitchel Dean Cochran

DAYS REQUESTED BY THIS EXTENSION: 2

DATE TO WHICH EXTENSION IS REQUESTED: 8-12-15

NUMBER OF EXTENSIONS PREVIOUSLY GRANTED: 1

I.

The Appellee's request is based upon the following reasonable explanation of the need for additional time, within the personal knowledge of Charles W. McDonald, the attorney signing this motion, T.R.A.P. 10.5(b), namely:

II.

Counsel has worked through the weekend and needs two additional days to complete this PDR. Counsel has been working under great strain the last 60 days due to the recent death of his father, his estate and winding down his practice. I would greatly appreciate the two days.

III.

WHEREFORE, this Attorney for the Appellant prays that the Court grant this motion and extend the time and deadline for the filing of Appellant's PDR for 2 weeks, or the Court grant such additional time as is just and proper.

Respectfully submitted,

/s/ Charles W. McDonald ATTORNEY AT LAW

2024 Austin Avenue Waco, Texas 76701 (254) 752-9901 FAX: (254) 754-1466 SBOTNO. 13538800

Mitchel Dean Cochran

CERTIFICATE OF SERVICE

The undersigned certifies that a true and correct copy of the above and foregoing instrument was served upon Abelino "Abel" Reyna, McLennan County Criminal District Attorney, 219 N. Sixth Street, Suite 200, Waco, Texas 76701-1363, according to rule and law, this 10th day of August, 2015.

/s/

Charles W. McDonald

Mitchel Dean Cochran