Sanders, Justin

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