Sanders, Justin

• Court: Court of Appeals of Texas
• Decided: September 14, 2015
• Docket: PD-1171-15
• Status: Published

Opinion

PD-1171-15 PD-1171-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS September 14, 2015 Transmitted 9/8/2015 1:52:21 PM Accepted 9/14/2015 10:45:33 AM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK OF TEXAS

JUSTIN SANDERS § § V. § CASE NO. 06-14-00079-CR § STATE OF TEXAS §

MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

The Appellant in the above-captioned case, through the undersigned attorney

of record, moves the Court for an extension of time in which to file his petition for

discretionary review pursuant to Rules 68.2(c) and 10.5(b) of the Texas Rules of

Appellate Procedure. As grounds therefore, the Appellant would show the Court the

following:

1. The Sixth Court of Appeals issued its memorandum opinion and judgment in

Justin Sanders v. State of Texas, No. 06-14-00079-CR, on August 12, 2015. No

motion for rehearing or en banc reconsideration was filed. Therefore, Appellant’s

petition for discretionary review is due September 11, 2015.

2. The Appellant is requesting an additional 30 days, or until October 12, 2015,

to file his petition for discretionary review.

3. The undersigned counsel was retained last week to represent the Appellant in

filing a petition for discretionary review. Counsel did not represent the Appellant in

Appellant's Motion for Extension of Time Page 1 of 3 the court of appeals. Rather, the Appellant was represented by court-appointed

counsel Craig L. Henry. This case involves a voluminous record and numerous

complex legal issues. Therefore, counsel needs additional time to obtain and review

the record and research the relevant law. This motion is not made for purposes of

delay, but in the interest of justice, to meet counsel’s obligations to her client and this

Court, and to accomplish the design of this appeal, which is to do substantial justice

to Appellant.

4. No previous extensions have been granted in this matter.

Respectfully submitted,

/s/ Gena Bunn Gena Bunn State Bar No. 00790323 Holmes & Moore, P.L.L.C. P.O. Drawer 3267 Longview, Texas 75606 Office No. (903) 758-2200 Facsimile No. (903) 758-7864 Email: gbunn@holmesmoore.com

Appellant's Motion for Extension of Time Page 2 of 3 CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing motion was

delivered by United States Mail, to Jerry Rochelle, Bowie County District Attorney,

Bowie County Plaza, 601 Main Street, Texarkana, Texas 75501, on this the 8th day

of September, 2015.

/s/ Gena Bunn Gena Bunn

Appellant's Motion for Extension of Time Page 3 of 3