Turner, Jimmy

• Court: Court of Appeals of Texas
• Decided: July 17, 2015
• Docket: PD-0893-15
• Status: Published

Opinion

PD-0893-15 PD-0893-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/17/2015 1:48:59 PM Accepted 7/17/2015 4:43:03 PM ABEL ACOSTA CLERK IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS AUSTIN, TEXAS

JIMMY TURNER Appellant

V. NO. 04-13-00886-CR

THE STATE OF TEXAS Appellee

Petition in Cause No. 2031-CR-6595-B and the Court of Appeals for the Fourth District of Texas.

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

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW Appellant, JIMMY TURNER, and pursuant to Rule 10.1 and Rule 10.5 of

the Texas Rules of Appellant Procedure, and files this Motion to Extend Time to File Petition for

Discretionary Review. In support of said motion, the Defendant would show as follows:

I.

On June 17, 2015, the Court of Appeals for the Fourth District of Texas affirmed the

judgment in Jimmy Turner v. The State of Texas, Cause No. 04-13-00886-CR. This cause had

been appealed from the 186^ Judicial District ofBexar County, Texas. Trial Court Number 2013-CR-6595-B.

July 17, 2015 II.

The Petition for Discretionary Review is due on July 17, 2015. The Appellant has not requested previous extensions in which to file Petition.

III. Appellant would show that the following are reasonable explanations for the requested

extension:

Appellant is filing a Petition for Discretionary Review Pro Se.

In order to have sufficient time to prepare Petition for Discretionary Review, Appellant

would request an extension to file Petition for Discretionary Review to October 7,2015.

Counsel consulted with the Bexar County Appellate Division and they have no objection

to this request.

WHEREFORE, PREMISES CONSIDERED, Appellant prays the court grant this motion

and allow Petition for Discretionary Review to be filed on October 7,2015.

Respectfully submitted,

LAW OFFICE OF PAMELA J. LAKATOS

PAMELA J.LAKlj^TOS TEXAS BAR CARD #04825600 3191 MEDICAL CENTER DRIVE APT 23105 MCKINNEY, TEXAS 75069 COUNSEL FOR APPELLANT JIMMY TURNER CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing motion was delivered to Bexar County District Attorney's Office, via email on July, 17,2015.

PAMELA J. LAKATOS r AFFIDAVIT OF PAMELA J. LAKATOS IN SUPPORT OF APPELLANT'S MOTION FOR ENLARGEMENT OF TIME wrnnN which t o file appellant's brief

STATE OF TEXAS §

COUNTY OF COLLIN §

BEFORE ME, the undersigned authority, personally appeared PAMELA J. LAKATOS, known to me to be the attorney ofrecord for JIMMY TURNER, in the capacity stated, and who after being duly sworn, deposed and said:

"My name is PAMELA J. LAKATOS. I am over the age of 21 years. I have personal knowledge of every statement herein and am fully competent and authorized to testify to these matters. I am licensed to practice law in the State of Texas. I am the attorney of record for JIMMY TURNER.

"I have read Appellant's Motion for Extension of Time Within Which to File Petition for Discretionary Review, and I swear and affirm that all of the information contained therein is true and correct to my knowledge."

FURTHER AFFIANT S AYETH NOT, Xi) _ . r\

PAMELA J. LAKATOS

SUBSCRIBED AND SWORN TO BEFORE ME the undersigned authority on this the Bk. day ofJuly 2015.

NOTARY PUBLIC IN AND FOR ROBERTS THE STATE OF TEXAS Notary Public STATE OF TEXAS MyComm. Esp.August 10.2017