Craver, Anthony Carl

Opinion

* PD-0825-15 PD-0825-15 COURT OF CRIMINAL APPEALS FILED IN AUSTIN, TEXAS COURT OF CRIMINALAPPEALS Transmitted 7/6/2015 12:35:54 PM Accepted 7/7/2015 3:20:41 PM ABEL ACOSTA

July 7, 2015 NO.

CLERK

ABELACOSTA, CLERK IN THE RT OF CRIMINAL APPEALS

OF TEXAS

ANTHONY CARL CRAVER

Petitioner

v.

THE STATE OF TEXAS

Respondent

Petition is in Cause No. 1272901D from Criminal District Court No. Two of Tarrant County, Texas, and Cause No. 02-14-00076-CR in the Court of Appeals for the Second District of Texas

MOTION TO FILE ENLARGED PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

COMES NOW, Anthony Carl Craver ("Petitioner"), who files his Motion to File

Enlarged Petition for Discretionary Review pursuant to Rule 9.4(i)(4) of the Texas

Rules of Appellate Procedure, and in support would respectfully show unto this

honorable Court the following:

Craver v. State - Motion to File Enlarged Petition for Discretionary Review Page 1 of 3

Petitioner has submitted concurrent with this Motion his Petition for

Discretionary Review. Exclusive of the pages containing the caption, identity of

parties and counsel, statement regarding oral argument, table of contents, index of

authorities, statement of the case, statement of issues presented, statement of

jurisdiction, statement of procedural history, signature, proof of service, certification,

certificate of compliance, and appendix, the Petition contains 5621 words, or 1,121

words over the page limit set forth in Rule 9.4(i)(2)(E) of the Texas Rules of

Appellate Procedure. See TEX. R. APP. P. 9.4(i)(2)(E).

The additional 1,121 words are necessary and should be allowed by this Court

for the following reasons:

1) the complexity of the legal and factual issues raised by the circumstances

of this case; and

2) were counsel required to omit 1,121 words of argument and analysis from

the instant Petition, the effectiveness of his representation might be severely

impacted and would interfere with the orderly administration of justice.

PREMISES CONSIDERED, Petitioner Anthony Carl Craver prays that this

Court grant this Motion in all respects, and allows him to file his Enlarged Petition

submitted concurrently with this Motion. Petitioner prays for any further relief to

Craver v. State - Motion to File Enlarged Petitionfor Discretionary Review Page 2 of 3 which he may be justly entitled.

Respectfully submitted,

/s/Abe Factor Abe Factor TBN: 06768500 Factor, Campbell & Collins Attorneys at Law 5719 Airport Freeway Fort Worth, Texas 76117 Phone: (817) 222-3333 Fax: (817) 222-3330 Email: lawfactor@yahoo.com Attorneys for Petitioner Anthony Carl Craver

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument has been furnished to counsel for the State's Prosecuting Attorney and the Tarrant County DistrictAttorney by a manner compliantwith the Texas Rules of Appellate Procedure, on this 6th day of Tuly_, 2015.

/s/Abe Factor Abe Factor

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