Green, Gary

• Court: Court of Appeals of Texas
• Decided: May 28, 2015
• Docket: PD-0644-15
• Status: Published

Opinion

PD-0644-15 PD-0644-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 5/28/2015 1:09:42 PM May 28, 2015 Accepted 5/28/2015 4:26:45 PM ABEL ACOSTA No. ___________ CLERK

In the COURT OF CRIMINAL APPEALS ______________________________________

On Appeal from the 390th Judicial District Court of Travis County, Texas Cause Number D-1-DC-12-202798; and the Opinion of the Thirteenth Court of Appeals in Cause Number 13-13-00418-CR, Delivered May 28, 2015 ______________________________________

GARY GREEN v. THE STATE OF TEXAS _____________________________________

MOTION FOR EXTENSION OF TIME TO FILE PRO SE PETITION FOR DISCRETIONARY REVIEW ______________________________

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL

APPEALS:

COMES NOW, Kristen Jernigan, the undersigned attorney of record for

Edward Guzman, the Appellant, herein, and files this Motion for Extension of

Time to File Pro Se Petition for Discretionary Review. As set out below, the

undersigned respectfully requests a sixty-day extension so that Appellant can file

his Pro Se Petition for Discretionary Review. In support of said motion, the

undersigned would show the Court the following:

1. Appellant’s Petition for Discretionary Review is currently due in this case on June 27, 2015. 2. Appellant seeks an extension of sixty days in which to file his Petition for Discretionary Review, making his Petition due on or before August 26, 2015.

3. The undersigned counsel will not be representing Appellant after the filing of this motion. Appellant will now have to obtain and review the record in order to prepare and file a Pro Se Petition for Discretionary Review. The undersigned believes that there is insufficient time between now and June 27, 2015, to accomplish those goals. Consequently, the undersigned respectfully requests that the Court grant Appellant the additional time.

4. The undersigned has not filed any previous motions for extension of time in this case.

5. For the reasons set forth above, the undersigned respectfully requests that Appellant be granted an extension of sixty days so that his petition for discretionary review in this case will now be due on August 26, 2015.

PRAYER

WHEREFORE, PREMISES CONSIDERED, the undersigned

respectfully requests that this Court grant this Motion for Extension of Time to File

Pro Se Petition for Discretionary Review.

Respectfully submitted,

_______/s/__Kristen Jernigan______ KRISTEN JERNIGAN State Bar Number 90001898 207 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 931-3650 (fax) Kristen@txcrimapp.com CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the

foregoing Appellant’s Motion for Extension of Time has been mailed to the Travis

County District Attorney’s Office, P.O. Box 1748, Austin, Texas 78767 on May

28, 2015.

__/s/ Kristen Jernigan__________________ Kristen Jernigan