Pitcock, Geoffrey Kevin

• Court: Texas Supreme Court
• Decided: September 1, 2015
• Docket: PD-1125-15
• Status: Published

Opinion

PD-1125-15 PD-1125-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/28/2015 4:44:54 PM Accepted 9/1/2015 9:57:48 AM ABEL ACOSTA CLERK IN THE COURT OF CRIMINAL APPEALS OF TEXAS

GEOFFREY KEVIN PITCOCK September 1, 2015 VS.

THE STATE OF TEXAS

FROM THE ELEVENTH COURT OF APPEALS

EASTLAND

NO. 11-13-00213-CR

APPEALED FROM TARRANT COUNTY CRIMINAL COURT THREE

TARRANT COUNTY, TEXAS

TRIAL NUMBER 1170491

MOTION TO EXTEND TIME OF FILING OF PETITION FOR DISCRETIONARY

REVIEW TO THE COURT OF CRIMINAL APPEALS.

This motion is brought by the Applicant GEOFFREY KEVIN PITCOCK, who moves the Court to permit him to file this Application late and would show the Court the following:

I

The opinion of the Court of Appeals is dated July 30, 2015. The correct statutory time for filing a Petition for Discretionary Review is within 30 days, August 28, 2015.

This motion is brought within 15 days of August 28, 2015.

II.

The attorney for the applicant has within the last 45 days served as chief counsel in two felony and several misdemeanor jury trials. The time and effort in the preparation of the aforementioned jury trials caused the counsel for the Applicant to not file the Petition for Discretionary Review within the 30 days. As a result of the aforementioned activities counsel for Appellant, reasonably believes that the Petitioner for Discretionary Review will be filed with this Court within thirty (30) days of the August 28, 2015, date.

The granting of this motion should not delay any action that would otherwise take place.

WHEREFORE PREMISES CONSIDERED, Applicant prays that this Court grant this request to file the Petition for Discretionary Review.

Respectfully submitted,

/s/ Abe Factor_____________________ Abe Factor Attorney for Appellant State Bar No. 06768500

FACTOR & CAMPBELL 5719 Airport Freeway Fort Worth, TX 76117 (817) 222-3333 (817) 222-3330 (fax) lawfactor@yahoo.com

CERTIFICATE OF SERVICE

I, ABE FACTOR, DO HEREBY CERTIFY THAT A TRUE AND CORRECT COPY OF THE ABOVE AND FOREGOING INSTRUMENT HAS BEEN DELIVERED TO THE ATTORNEY FOR THE STATE AND TO THE STATE PROSECUTING ATTORNEY AUSTIN, TEXAS.

On this the 28th day of August, 2015.

/s/ Abe Factor_____________________ Abe Factor