PD-0443-16 PD-0443-16
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
June 2, 2016 Transmitted 6/2/2016 2:25:17 PM
Accepted 6/2/2016 4:13:56 PM
ABEL ACOSTA
IN THE COURT OF CRIMINAL APPEALS
CLERK
FOR THE STATE OF TEXAS
ROLANDO BARRAGAN *
Appellant *
* COA#
vs. * No. 10-15-00079-CR
*
THE STATE OF TEXAS *
Appellee
MOTION FOR EXTENSION OF TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF APPEALS:
COMES NOW, the Appellant, by and through her undersigned Attorney of
Record, and respectfully moves the Court to extend the time for filing a petition for
discretionary review in this cause, and in support therefore would show the Court as
follows:
I.
That Appellant was found guilty of the offense of Indecency of a Child, No.2011-
1161-C1 in the 19th District Court of McLennan County, Texas. Appellant was
sentenced by the court and timely gave notice of Appeal.
II.
Appellant’s petition for discretionary review is currently due on June 1, 2016.
III.
Appellant hereby requests an extension of time to file his Petition for Discretionary
Review until June 2, 2016, and as reasons therefore would show this cause as follows:
Counsel was unable to complete the petition for discretionary review by the current
due date.. Counsel has had a medical issue that has required a substantial amount of time
to resolve over the last several days. The petition was almost done, but counsel had to be
out of the office on June 1, and was unable to get it submitted. The petition is being
submitted with this motion.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests this
honorable court to extend the time for filing Appellant's Petition for Discretionary Review
in this cause to June 2, 2016.
Respectfully submitted,
/s/ Walter M. Reaves, Jr.
Walter M. Reaves, Jr.
100 N. 6 th Street, Suite 802
Waco, Texas 76701
(254) 296-0020
FAX (877) 726-4411
TBA#16644200
walterreaves@att.net
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing motion was delivered
to Abel Reyna, District Attorney for McLennan County, Texas, on June 2, 2016.
/s/ Walter M. Reaves, Jr.
Walter M. Reaves, Jr.