Shakesnider, Jeremy Patrick

Opinion

PD-1393-15

PD-1393-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 10/27/2015 2:48:15 PM October 27, 2015 Accepted 10/27/2015 5:15:06 PM ABEL ACOSTA

No. ___________ CLERK

In the

COURT OF CRIMINAL APPEALS

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On Appeal from the 400th Judicial District Court of Fort Bend County, Texas, Cause Number 11-DCR-59007A;

and the Opinion of the Fourteenth Court of Appeals in Cause Number 14-14-00272-CR, Delivered October 15, 2015

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JEREMY PATRICK SHAKESNIDER v.

THE STATE OF TEXAS

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MOTION FOR EXTENSION OF TIME TO FILE PRO SE PETITION FOR DISCRETIONARY REVIEW

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TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL

APPEALS:

COMES NOW, Michael Elliott, the undersigned attorney of record for

Jeremy Patrick Shakesnider, the Appellant, herein, and files this Motion for

Extension of Time to File Pro Se Petition for Discretionary Review. As set out

below, the undersigned respectfully requests a thirty-day extension so that

Appellant can file his Pro Se Petition for Discretionary Review. In support of

said motion, the undersigned would show the Court the following:

1. Appellant’s Petition for Discretionary Review is currently due in this case on November 14, 2015.

2. Appellant seeks an extension of thirty days in which to file his Petition for Discretionary Review, making his Petition due on or before December 14, 2015.

3. The undersigned counsel will not be representing Appellant after the filing of this motion. Appellant will now have to obtain and review the record in order to prepare and file a Pro Se Petition for Discretionary Review. The undersigned believes that there is insufficient time between now and November 15, 2015, to accomplish those goals. Consequently, the undersigned respectfully requests that the Court grant Appellant the additional time.

4. The undersigned has not filed any previous motions for extension of time in this case.

5. For the reasons set forth above, the undersigned respectfully requests that Appellant be granted an extension of thirty days so that his brief in this case will now be due on December 15, 2015.

PRAYER

WHEREFORE, PREMISES CONSIDERED, the undersigned

respectfully requests that this Court grant this Motion for Extension of Time to File

Pro Se Petition for Discretionary Review.

Respectfully submitted,

_______/s/__Michael Elliott______ Michael Elliott State Bar Number 06546540 905 Front Street Richmond, Texas 77469 (832) 496-5000 (281) 232-8141 (fax) mike@elliottslaw.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the

foregoing Appellant’s Motion for Extension of Time has been mailed to the Fort

Bend County District Attorney’s 301 Jackson Street, Richmond, Texas 77469 on

October 27, 2015.

__/s/ Mike Elliott__________________ Mike Elliott