PD-0052-15
PD-0052-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
JANUARY 20, 2015 Transmitted 1/13/2015 1:10:01 PM
Accepted 1/20/2015 5:22:50 PM
ABEL ACOSTA
NO. __________________ CLERK
JULIA RHOTON ANDREWS § IN THE COURT OF
§
VS. § CRIMINAL APPEALS
§
STATE OF TEXAS § OF TEXAS
MOTION TO EXTEND TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
Now comes Julia Rhoton Andrews, Appellant in the above styled and
numbered cause, and moves for an extension of time of 30 days to file a
petition for discretionary review, and for good cause shows the following:
1. On December 10, 2014, the Court of Appeals affirmed
appellant's conviction. Julia Rhoton Andrews v. State, 09-13-00407-CR.
This petition is therefore due on January 10, 2015.
2. Counsel has been unable to complete the petition for the
following reasons: Counsel for Appellant has been laboring under a heavy
caseload and requires more time to prepare said brief and requests more
time to file said PDR.
3. Defendant is currently incarcerated.
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WHEREFORE, PREMISES CONSIDERED, appellant respectfully
requests an extension of 30 days, i.e. until February 11, 2015, to file a
petition for discretionary review.
Respectfully submitted,
CHRISTINE R BROWN-ZETO
Attorney at Law
1107 Green Avenue
Orange, Texas 77630
Tel: (409) 886-8558
Fax: (409) 883-6523
By: /S/ Christine R. Brown-Zeto
Christine R. Brown-Zeto
State Bar No. 03102200
crbrown@exp.net
Attorney for Julia Rhoton Andrews
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, Orange County, 801 Division, Orange, Texas 77630, by mail.
/S/ Christine R. Brown-Zeto
Christine R. Brown-Zeto
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