Smith, Jacob Brent

Opinion

PD-1599-15 PD-1599-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/9/2015 9:43:46 AM Accepted 12/11/2015 10:37:40 AM ABEL ACOSTA PD No: - - - - - - CLERK

JACOB BRENT SMITH IN THE TEXAS COURT

vs. OF CRIMINAL APPEALS

STATE OF TEXAS AUSTIN, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S PRO-SE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW, Appellant, by and through the undersigned attorney, who has

personal knowledge of the matters contained herein, and files this Motion for Extension of

Time to File Appellant's Pro-Se Petition for Discretionary Review, and in support thereof

would show:

I.

Appellant was convicted of evading arrest or detention in a vehicle and sentenced to

30 years in the Texas Department of Criminal Justice - Institutional. The trial court was

the 185th District Court of Harris County, Texas. The trial court cause number was:

1410410. On December 1, 2015, the Fourteenth Court of Appeals in Houston, Texas,

affirmed appellant's conviction in appellate cause number: 14-14-00681-CR.

II.

The current deadline for filing appellant's Petition for Discretionary Review is

December 31, 2015.

December 11, 2015 III.

No previous extension of time to file a Petition for Discretionary Review has been

requested by appellant.

IV.

The undersigned is not pursuing further appellate review on behalf of Mr. Smith. The

undersigned is notifying appellant of his right to pursue a Petition for Discretionary Review

in this Court.

v. Appellant is requesting an additional thirty (30) day extension until February 1, 2016

in which to file his pro-se Petition for Discretionary Review in this matter.

VI.

This request is not made for the purpose of delay but to insure Appellant's right to

appellate review in this matter.

VII.

Appellant's last known address within the Texas Department of Criminal Justice is:

Mr. Jacob Brent Smith TDCJ-ID # 1947387 Eastham Unit 2665 Prison Road 1 Lovelady, Texas 75851

WHEREFORE, PREMISES CONSIDERED, the undersigned prays that the Court

grant this Motion for Extension of Time to File Appellant's Pro-Se Petition for

Discretionary Review until February 1, 2016. Respectfully submitted,

w~ SBOT: 09656300 4615 Southwest Freeway, Suite 600 Houston, Texas 77027 (713) 623-8312 wthlaw@aol.com

CERTIFICATE OF SERVICE

A true and correct copy of this motion was mailed to:

Harris County District Attorney's Office Appellate Division 1201 Franklin, 61h Floor Houston, Texas 77002

Mr. Jacob Smith (Address noted above)