PD-0048-15
COURT OF CRIMINAL APPEALS
JANUARY 16, 2015
PD-0048-15 AUSTIN, TEXAS
Transmitted 1/12/2015 3:15:54 PM
Accepted 1/16/2015 4:57:13 PM
IN THE COURT OF APPEALS ABEL ACOSTA
ELEVENTH DISTRICT OE TEXAS CLERK
KIM FINLEY § 11-13-00050-CK
§
vs. §
§
§
STATE OF TEXAS §
APPELLANT'S MOTION TO EXTEND TIME
TO THE HONORABLE JUDGE OF THE SAID COURT,
Comes now. Appellant, Kim Finlcy, and files this Motion to Extend Time and would
show the following:
1. The Appellant's Petition for Discretionary Review is due January 12, 2(115.
Appellant respectfully requests an extension until March 13, 2015 to file her petition.
Counsel for Appellant was engaged in a murder trial (State of Texas v. Lavhvla
Schoonover, Tarrant County Cause Number 1338474) when the Memorandum Judgment
was issued, thus delaying communication to the incarcerated client.
2. Appellant will exercise diligence to ensure that this Petition will be filed at the
earliest practicable time.
WHEREFORE, premises considered, the Appellant respectfully asks this Court to
grant this extension pursuant to Tex. R. App. P. (i8.2(c).
Respectfully submitted,
Scott, McNeill & Burney, PLLC
3000 East U)op82()
Ft Worth, Texas 76112
(817)534-8000
(817) 851-1404 fax
By: /s/ Mark D. Scott_
Mark D. Scott
State Bar No. 24043911
Attorney Tor Appellant
CERTIFICATE OF SERVICE
This is to certify that on January 12, 2015, a true and correct copy of the above
and foregoing document was served on the District Attorney's Office by facsimile to
(817)884-1672.
_/s/ Mark D. Scott
Mark D. Scott
Stale Bar No. 24043911
Attorney for Appellant
3000 East Loop 820
Ft Worth, Texas 76112
(817)534-8000
(817)851-1404 fax
markscottlaw(«;yahoo.com
CERTIFICATE OF CONFERENCE
Prior to presenting this matter to the Court for Approval, I contacted Alice
London, of the Tarrant County District Attorney's Office Appellate Section via telephone
on 1/12/15. Ms. London slated that the Tarrant County District Attorney's Office had no
objection to this motion.
_/s/ Mark D. Scott
Mark D. Scott
3000 Fast Loop 820
Ft Worth Texas 76112
(817)534-8000
(817) 85 1-1404 fax
markscottlaw(«;yahoo.com
State Bar No. 24043911