Marquez, Christopher Daniel

CourtCourt of Appeals of Texas
DecidedAugust 27, 2015
DocketPD-1111-15
StatusPublished

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Bluebook
Marquez, Christopher Daniel, (Tex. Ct. App. 2015).

Opinion

PD-1111-15

CAUSE NO.

CHRISTOPHER DANIEL MARQUEZ, § IN THE COURT OF Petitioner,! §

FILEdTlN § . CRIMINAL APP^^|V|D^^ COURT OF CRIMSMMPPttLffEXAS, OF TEXAS n 0P1, Res*ondent' § AUG 272015 27 £ji3 , MOTION FOR EXTENSION OF TIME TO FILE rw Abel Acosta, CierK PETITION FOR DISCRETIONARY REVIEW Abe! Acosta . G»e- .^, TO THE HONORABLE COURT:

Comes now, Christopher Daniel Marquez, Petitioner in the above styled case for Petition for Discretionary REview, pursuant to the Texas Rules of Appellate Procedure Rule 68.2 (c) and Rule 10.5 (b) and would request an extension of time for good cause and would show the following:

1. The deadline for filing the Petition for Discretionary Review is on or about August 30, 2015; 2. Petitioner seeks a sixty (60) day extension which would extend his deadline for filing to on or about October 30, 2015; 3. Petitioner is incarcerated, acting in pro se, and for all practicle purposes indigent .Petitioner, was appointed appellate counsel on appeal. Petitioner is not a trained and skilled attorney and therefore he would require more time to research, execute and file his Petition for Discretionary Review and by Texas Department of Criminal Justice policy they will not make copies for any inmate and so they would have to be sent out to comply with Texas Rules of Appellate Procedure Rule 9.3 (b)(1) original and 11 copy rule which would take time; 4. This is Petitionee's first request for extension of time for this instant proceeding and no other previous extensions have been granted for this item; 5. Petitionee's appeal was affirmed by the Eleventh Court of Appeals, at Eastland, Texas. 6. The Court of Appeals judgment was decided on July 31, 2015. 7. The case number in the Court of Appeals was 11-13-00192-CR and the style was Christopher Daniel Marquez v The STate of Texas. 8. There has been no extensions of time for rehearing or any Motions for Reconsideration en banc and nothing pending in the Eleventh Court of Appeals in Eastland, TExas. PRAYER

Petitioner prays that this Honorable Court will Grant his Motion For Extension of Time To File Petition For Discretionary Review or whatever this Court deems necessary in the interest of justice.

Respectfully submitted,

(ZkrCS yi<->rg.,,r-ZL Christopher Daniel Marquez TDCJ No. 1865294

Telford Unit

3899 State Highway 98 New Boston, Texas 75570

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Motion has been served on the State of Texas by and through it's attorney of record, District Attorney of HOward County, Hon. Hardy Wilkerson, :118th District Attorney, at P.O. DRawer 149, Big Spring, Texas 79701 and the State Prosecuting Attorney, Lisa C. Mcminn, at P.O. BOx 12405 Capitol Station, Austin, Texas 78711-2308 by pre paid postage U.S. Mail and placed in the prison mailbox on August 19, 2015.

^IT» *• J «. J_ _ — L ___ t^ « • Christopher DAniel Marquez Petitioner pro se

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Marquez, Christopher Daniel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marquez-christopher-daniel-texapp-2015.