PD-0564-16 PD-0564-16
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/20/2016 10:36:54 AM
Accepted 5/20/2016 3:16:08 PM
ABEL ACOSTA
No. _____________ CLERK
In the
Court of Criminal Appeals
At Austin
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No. 14-15-00254-CR
In the
Court of Appeals
for the
Fourteenth District of Texas
at Houston
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No. 1396938
May 20, 2016 In the 178th District Court
Harris County, Texas
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ALFREDO RAMIREZ
Appellant
V.
THE STATE OF TEXAS
Appellee
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APPELLANT’S MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE
PETITION FOR DISCRETIONARY REVIEW
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TO THE HONORABLE COURT OF APPEALS:
APPELLANT, Alfredo Ramirez, pursuant to TEX. R. APP. P. 68.2(c)
moves for an extension of time within which to file its petition for
discretionary review. In support of its motion, appellant submits the
following:
1. Appellant was charged with felony assault on a family member by
impeding breathing.
2. A jury found Appellant guilty and the Court sentenced him on
March 2, 2015 to 20 years confinement in the Texas Department
of Corrections Institutional Division.
3. A unanimous panel of the Fourteenth Court of Appeals rendered
judgment in an unpublished opinion on April 21, 2016, affirming
appellant’s conviction and sentence.
4. Appellant’s petition for discretionary review is due May 21, 2016.
5. Appellant seeks an extension, in accordance with TEX. R. APP.
P. 68.2(c), until June 21, 2016, to file its petition for discretionary
review. This is appellant’s first request for an extension.
6. Petitioner is presently incarcerated in TDCJ and counsel needs
additional time to prepare his petition for discretionary review due
to her current caseload. Appellant’s petition is not for purposes of
delay, but so that justice may be done.
WHEREFORE, the Appellant prays that this Court will grant the
requested extension until June 21, 2016.
Respectfully submitted,
s/Tonya Rolland McLaughlin
Tonya Rolland McLaughlin
1523 Yale Street
Houston Texas 77008
Phone: (713) 529-8500
Fax: (713) 453-2203
TBN 24054176
tonya@rollandlaw.com
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been
emailed to the following:
kugler_eric@dao.hctx.net
Appellate Division
Harris County District Attorney’s Office
1201 Franklin Suite 600
Houston, Texas 77002-1923
_/s/ Tonya Rolland McLaughlin__
Tonya Rolland McLaughlin