Saunders, Marc Richard

• Court: Court of Appeals of Texas
• Decided: December 18, 2015
• Docket: PD-1640-15
• Status: Published

Opinion

PD-1640-15 PD-1640-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/17/2015 3:05:36 PM Accepted 12/19/2015 9:41:55 AM ABEL ACOSTA Appellate No. 09-14-00062-CR CLERK

MARC RICHARD SAUNDERS § IN THE TEXAS COURT OF § CRIMINAL APPEALS § VS. § § STATE OF TEXAS §

MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes MARC RICHARD SAUNDERS, Appellant in the above styled and

numbered cause, and moves this Court to grant an extension of time to file

appellant's Petition for Discretionary Review and for good cause shows the

following:

1. This case is on appeal from the Ninth District Court of Appeals in

Beaumont, styled MARC RICHARD SAUNDERS vs. STATE OF TEXAS

and was given Appellate No. 09-14-00062-CR.

2. The Court of Appeals' judgment was signed November 18, 2015.

3. The deadline to file Petition for Discretionary Review is December

18, 2015.

December 18, 2015 Saunders' Motion to Extend Time to File PDR 1 of 3 4. Appellant requests an extension of time until January 18, 2016 or

a time period of at least 30 days.

5. Appellant has not requested any prior extensions regarding

petition for discretionary review.

6. Appellant relies on the following facts as good cause for the

requested extension:

Counsel is a solo practitioner and has been involved in or prepared for the

following criminal trials, appeals or motions:

(i) Montgomery County, State of Texas v. Mike Angel Ulloa, 221st District Court, 14-02-02317-CR, Tampering; Writ of Habeas Corpus Appeal, Beaumont Court of Appeals, 9th District, 09-15-00398-CR

(ii) United States District Court Southern District of Texas, United States v. Darnell Menard, 15cr296-01 , Judge Atlas Houston, Conspiracy, and multiple counts of fraud related activity under 18 USC 1029(a)(2);(a)(3); and (b)(2).

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court

grant this Motion To Extend Time to File Petition for Discretionary Review, and

for such other and further relief as the Court may deem appropriate.

Saunders' Motion to Extend Time to File PDR 2 of 3 Respectfully submitted

/S/ Richard Martin P. Canlas RICHARD MARTIN P. CANLAS Lawyer for Appellant 300 West Davis, Suite 560 Conroe, Texas 77301 Texas State Bar Number: 90001843 Tel: 936.788.6999 Fax Number: 936.788.5999

Certificate of Service

I certify that a true and correct copy of this motion was:

(a) faxed to Bill Delmore, Montgomery County District Attorney’s Office, 936.760.6940, on December 17, 2015

/S/ Richard Martin P. Canlas Richard Martin P. Canlas

Saunders' Motion to Extend Time to File PDR 3 of 3