Diaz, Daniel

PD-0035-15 COURT OF CRIMINAL APPEALS PD-0035-15 AUSTIN, TEXAS Transmitted 1/6/2015 4:57:32 PM Accepted 1/15/2015 3:37:50 PM PDR NO. ABEL ACOSTA CLERK IN TIIE COURT OF'CRIMINAL APPEALS DANIEL DIAZ, Appellant vs. JANUARY 15, 2015 THE STATE OF TEXAS, Appellce On Appeal from thc 253RD Judicial l)istrict Court Liberty County, Texas Trial Court Cause No. CR29411 And The Court of Appeals for the Ninth Judicial District of Texas Beaumont, Texas No. 09-13-00104-CR APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE I]ONORABL]] JUSTICES OF SAID COURT: COMES NOW, DANIEL DIAZ, Appellant and files this, his Molion 1o Extend Tirne to File Petitior.r for Discretionary Review for thirty (30) days and for good cause would show the Court as follows: t. On Irebruary 28, 2013, the appellant was convicted of the offense of Official Oppression in the 253'd Judicial District Court of Liberty County, Texas in Cause No. CM941l. 'l-his case was styled State of 1-exas v. Daniel Diaz. The appellant rvas assessed a punishment of one year in the Liberty County Jail facility. The notice of appeal was timely filed on March 1, 2013. On October 22,2014, the Court of Appeals for the Ninth Judicial District, Beaumont, Texas, affirmed the conviction in Cause No. 09-13-00104-CR. Appellant filed a Motion for Rehearing on Novetnber 2t,2014. This motion was overruled on December I0,2014. The Petition for Discretionary Review is due on January 9,2015. II. Appellant requests an extension based upon the following facts: Counsel was hired by the Appellant in late Decetnber of 2014 to submit a pelition for discretionary review in this cause. Counsel is looking at this case for the first time, as other attorneys conducted the trial as well as the direct appeal in the Court of Appeals for the Ninth Judicial District. Counsel needs additional time 1o review the record on appeal, review the briefs filed in the Court ofAppeals, and to flush out the issues involved in this case. 'I'his rnotion is nrade pursuant to Tex. R. App. Proc. 68.2(c), additionally cornplying with Rule 10.5(b) (filed no later than 15 days after the last date for filing the rnotion). WI-IEREFORE, PREMISES CONSIDERED, appellant respectfully prays that the court grant this rnotion and extend the time for filing his Petition for Discretionary Review for thirty days liorn January 9, 2015 to February 9.2015' 2 Rcspcctfully submitted, WENDELL A. ODOM, Tcxas Bar No. 15208500 440 Louisiana Street, Suite 200 Houston, Texas 77002 (713)223-ss7s (713) 224-281s FAX CERTIFICATE OF SERVICE I hereby cedify that a true and correct copy of the foregoing Motion was delivered to the Court of Appeals, a copy being sent to the Assistant District Attorney in this cause by electronic transmission. ilkW WENDELL A. ODOM, JR. 3 S'IATE OF TEXAS s s COUNTY OF I{ARRIS s On this day personally appeared WENDELL A. ODOM, JR., who slated under oath as follows: "My name is WENDELL A. ODOM, JR. I arn 1he allorney of record for the Appellant in this cause. I have read the foregoing Motion for an Extcnsion of Time to File Pctition for Discretionary Review, and swear that thc nattcrs contained in such motion are true and corecl. " WDNDELLA. ODOM, SWORN TO AND SUBSCRIBED before me on this the r/, ';/d ay of ryrU 2015, to which witness my hand and seal of office a MARY C MOORE OTARY UBLI IN AND F'OR NOTARY FUBLIO. STATE OF TEXAS MY COMMISSION EXPIRES THE ST E OF'TEXAS SEPT. 3, 2016 4 IN THE COI]ITT OF CRIMINAL APPEALS DANIEL DIAZ, s Appellant s s PDRNO. $ vs. s COURT OF APPEALS NO. s 09-13-00104-cR THE STATE OF TEXAS, $ TRIAL DOCKET NO. CR294I1 Appellec s ORDER On this day came on to be heald Appellant's Motion for Extension of Timc to Filc Pctition for Discretionary Rcvicw. It is the opinion of this Court thal the Motion to Extend Time to File Pctition for Discrctionary llcview should be and is hereby GRANTED, and it is therefore ORDERB,D, ADJUDGED and DECREED that the Appellant's Petition for Discretionary Review is due to be filed in this Court on day of 201s SIGNED on this the day of 2015 JUDGE PRESIDING 5