Ritcherson, Kaitlyn Lucretia

Opinion

PD-1286-15 PD-1286-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/28/2015 2:48:25 PM Accepted 9/30/2015 2:03:37 PM ABEL ACOSTA PDR No. ____________________ CLERK

Court of Appeals No. 03-13-00804-CR

KAITLYN RICHERSON § IN THE TEXAS COURT OF § v. § CRIMINAL APPEALS § STATE OF TEXAS § AT AUSTIN, TEXAS

PETITIONER’S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes KAITLYN RITCHERSON, Petitioner in the above styled and

numbered cause, and moves this Court for a 90-day extension to file her Petition

for Discretionary Review, and would show as follows:

1. Petitioner has been convicted for the offense of Murder and has been

assessed a sentence of 25 years.

2. The Third District Court of Appeals issued an published decision in

this case on August 31, 2015. Kaitlyn Lucretia Ritcherson v. State of Texas, 03-

13-00804 (Tex.App.- Austin, August 31, 2015). The PDR in this case is due on

or before October 1, 2015.

3. Petitioner requests an additional 90 days from the present due date to

file a Petition for Discretionary Review. As good cause, Petitioner would show

that the undersigned counsel is reviewing the case to determine the best issue(s) in

September 30, 2015 1 which to raise in a Petition for Discretionary Review. In addition to the present

case, counsel has had the following appellate matters which have become due

during the month of September:

a. USA v. Alberto Moncivais-Almendar – appeal was filed in the

5th Circuit Court of Appeals on September 25, 2015;

b. USA v. Rachel Hardy – appeal is due to be filed in the 5th

Circuit Court of Appeals on September 25, 2015; and,

c. State of Texas v. Preston Sharpnack – PDR was filed in this

Court on or about September 10, 2015.

In addition to the foregoing, counsel will have the following appellate

matters throughout the months of October and November:

a. State of Texas v. Anthony Robertson– PDR is due in this Court

on October 21, 2015;

b. State of Texas v. Ricky Ellison – PDR is due in this Court on

November 12, 2015;

c. State of Texas v. Reynaldo Zamora – appeal is due in First

District Court of Appeals in late October or early November

2015;

d. USA v. Rickey Benns – counsel is scheduled for oral argument

2 before the 5th Circuit Court of Appeals in New Orleans on

November 6, 2015.

e. Counsel will be out of the country on a pre-scheduled CLE

from November 15 through 21, 2015.

6. Accordingly, the undersigned counsel requests this Court extend the

deadline to file the PDR in this case by 90 days from the current due date.

WHEREFORE, PREMISES CONSIDERED, Petitioner prays that this

Court grant this Motion, and grant an additional 90 days to file a PDR in this case

Respectfully submitted,

Law Office of Alexander L. Calhoun 4301 W. William Cannon Dr., Ste. B-150, # 260 Austin, TX 78749 Tele: 512/ 420-8850 Fax: 512/ 233 - 5946 Cell: 512/ 731-3159 Email: alcalhoun@earthlink.net

BY:_/s/ Alexander L Calhoun Alexander L. Calhoun State Bar No.: 00787187

Attorney for Kaitlyn Lucretia Ritcherson

3 CERTIFICATE OF SERVICE

I hereby certify that on September 28, 2015, a copy of the above and foregoing

motion has been served by mail upon the Travis County District Attorney's Office, at the

following address:

Travis County District Attorney P.O. Box 1748 Austin, TX 78767

upon the State Prosecution Attorney by U.S. Mail at the following address:

State Prosecuting Attorney P.O. Box 13046 Capitol Station Austin, Texas 78711

/s/ Alexander L Calhoun Alexander L. Calhoun