Ramirez, Alfredo

• Court: Court of Appeals of Texas
• Decided: May 20, 2016
• Docket: PD-0564-16
• Status: Published

Opinion

PD-0564-16 PD-0564-16 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 5/20/2016 10:36:54 AM Accepted 5/20/2016 3:16:08 PM ABEL ACOSTA No. _____________ CLERK In the Court of Criminal Appeals At Austin ⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯

No. 14-15-00254-CR

In the Court of Appeals for the Fourteenth District of Texas at Houston

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No. 1396938 May 20, 2016 In the 178th District Court Harris County, Texas

ALFREDO RAMIREZ Appellant V. THE STATE OF TEXAS Appellee ⎯⎯⎯⎯♦⎯⎯⎯⎯

APPELLANT’S MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE PETITION FOR DISCRETIONARY REVIEW

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TO THE HONORABLE COURT OF APPEALS:

APPELLANT, Alfredo Ramirez, pursuant to TEX. R. APP. P. 68.2(c)

moves for an extension of time within which to file its petition for

discretionary review. In support of its motion, appellant submits the

following: 1. Appellant was charged with felony assault on a family member by impeding breathing. 2. A jury found Appellant guilty and the Court sentenced him on March 2, 2015 to 20 years confinement in the Texas Department of Corrections Institutional Division. 3. A unanimous panel of the Fourteenth Court of Appeals rendered judgment in an unpublished opinion on April 21, 2016, affirming appellant’s conviction and sentence.

4. Appellant’s petition for discretionary review is due May 21, 2016. 5. Appellant seeks an extension, in accordance with TEX. R. APP. P. 68.2(c), until June 21, 2016, to file its petition for discretionary review. This is appellant’s first request for an extension.

6. Petitioner is presently incarcerated in TDCJ and counsel needs additional time to prepare his petition for discretionary review due to her current caseload. Appellant’s petition is not for purposes of delay, but so that justice may be done.

WHEREFORE, the Appellant prays that this Court will grant the

requested extension until June 21, 2016.

Respectfully submitted,

s/Tonya Rolland McLaughlin Tonya Rolland McLaughlin 1523 Yale Street Houston Texas 77008 Phone: (713) 529-8500 Fax: (713) 453-2203 TBN 24054176 tonya@rollandlaw.com CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been emailed to the following:

kugler_eric@dao.hctx.net Appellate Division Harris County District Attorney’s Office 1201 Franklin Suite 600 Houston, Texas 77002-1923

_/s/ Tonya Rolland McLaughlin__ Tonya Rolland McLaughlin