Escobar, Tony

• Court: Court of Appeals of Texas
• Decided: November 18, 2015
• Docket: PD-1498-15
• Status: Published

Opinion

PD-1498-15 PD-1498-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/17/2015 5:46:55 PM November 18, 2015 Accepted 11/18/2015 3:05:49 PM ABEL ACOSTA PD No:- - - - - - CLERK

TONY ESCOBAR IN THE TEXAS COURT

vs. OF CRIMINAL APPEALS

STATE OF TEXAS AUSTIN, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW, Appellant, Tony Escobar, by and through the undersigned attorney,

and files this Motion for Extension of Time to File Appellant's Petition for Discretionary

Review, and in support thereof would show:

I.

Appellant was convicted of capital murder and sentenced to life in the Texas

Department of Criminal Justice - Institutional Division. The trial court was the 33gth District

Court of Harris County, Texas. The trial court cause number was 1344348. On October 29,

2015, the First Court of Appeals in Houston, Texas, affirmed appellant's conviction in

appellate cause number 01-14-00593-CR.

II.

The current deadline for filing appellant's petition for discretionary review is

November 30, 2015.

III.

No previous extension of time to file a petition for discretionary review has been

requested by appellant. IV.

The undersigned visited Appellant at the Connally Unit in Kenedy, Texas, to discuss

the Opinion issued by the First Court of Appeals. Additional time is needed for the

undersigned to evaluate the potential issues to be presented to this Court on petition for

discretionary review. The undersigned is also requesting this extension due to trial and

appellate scheduling conflicts which prevent him from completing a petition for

discretionary review by the current due date.

v. Appellant is requesting an extension until December 28, 2015 in which to file a

petition for discretionary review in this matter

VI.

This request is not made for the purpose of delay but to insure Appellant's right to

appellate review in this matter.

WHEREFORE, PREMISES CONSIDERED, the undersigned prays that the Court will

grant this Motion for Extension of Time to File Appellant's Petition for Discretionary Review

until December 28, 2015.

Respectfully submitted,

w~ SBOT: 09656300 4615 Southwest Freeway, Suite 600 Houston, Texas 77027 Tel: (713) 623-8312 Fax: (713) 626-0182 email: wthlaw@aol.com BEFORE ME, the undersigned authority, on this day personally appeared Wayne T. Hill, who after being duly sworn by me, upon his oath did state that the information ) contained in the above \MQfMm for extension of ime is true and c rrect. ( 1I - I - 2 o / 5 ,,,,,~\P.. HIJ 111111,, ~ ,,, -' \P •·· •· ··· ~0,,.",, .$' ~'....o\ARy ";:,·.. ·y ~ ...~S' .:... ~*&;.,·.~~ V' '· \1\~ o::o== t:- ~rn::. 2 : = :~ ":: ~ 7,A' : ~ ~ \('" C:J." $ ~ v. ··f-t; Of:rE'f..lf. .•/ 1- 0: '• .t:>IRES ~ .:;:; ;,'l_, 'A.·.. ' V.t-. ........ ..·· \-.;~ < 2.Qi6 I'/ <.,,,' 1111 ,, 111i 11 kitiR'fIFICATE OF SERVICE

A true and correct copy of this motion will be delivered to:

Harris County District Attorney' s Office Appellate Division 1201 Franklin, 61h Floor Houston, Texas 77002