PD-0071-15
PD-0071-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 1/16/2015 11:53:22 AM
Accepted 1/22/2015 12:11:19 PM
ABEL ACOSTA
No. 04-13-00754-CR CLERK
TO THE COURT OF CRIMINAL APPEALS
OF THE STATE OF TEXAS
JOSE ANGEL FLORES, JR., Appellant
v.
THE STATE OF TEXAS, Appellee
Appeal from Guadalupe County
* * * * *
STATE’S MOTION TO EXTEND TIME FOR
FILING ITS PETITION FOR DISCRETIONARY REVIEW
* * * * *
Lisa C. McMinn
January 22, 2015 State Prosecuting Attorney
Bar I.D. No. 13803300
Stacey M. Goldstein
Assistant State’s Attorney
Bar I.D. No. 24031632
P.O. Box 13046
Austin, Texas 78711
information@spa.texas.gov
512-463-1660 (Telephone)
512-463-5724 (Fax)
No. 04-13-00754-CR
TO THE COURT OF CRIMINAL APPEALS
OF THE STATE OF TEXAS
JOSE ANGEL FLORES, JR., Appellant
v.
THE STATE OF TEXAS, Appellee
* * * * *
STATE’S MOTION TO EXTEND TIME FOR
FILING ITS PETITION FOR DISCRETIONARY REVIEW
* * * * *
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
The State Prosecuting Attorney respectfully submits its motion to extend the
time for filing its Petition for Discretionary Review.
Pursuant to Rule of Appellate Procedure 68.2(c), the State moves to extend the
time for filing its petition until February 15, 2015—30 days after the current due date
of January 16, 2015. No previous motions to extend the deadline for filing have been
filed. This is a mandatory blood-draw case that will be controlled by the Court’s
ruling on the pending motion for rehearing in State v. Villarreal, No. PD-0306-14.
Given the unique procedural circumstances implicated here, counsel believes that the
interests in judicial economy warrant granting an extension so that it can be
determined whether the filing of a petition for discretionary review is necessary.
Additionally, counsel needs additional time to review the record and draft the
petition.
WHEREFORE, the State prays that its motion to extend the time for filing its
petition for discretionary review until February 15, 2015, be granted.
Respectfully submitted,
Lisa C. McMinn
State Prosecuting Attorney
Bar I.D. No. 13803300
/s/ STACEY M. GOLDSTEIN
Assistant State Prosecuting Attorney
Bar I.D. No. 24031632
P.O. Box 13046
Austin, Texas 78701
information@spa.texas.gov
512-463-1660 (Telephone)
512-463-5724 (Fax)
CERTIFICATE OF SERVICE
A copy of the State’s Motion to Extend the Time for Filing its Petition for
Discretionary Review has been served on January 16, 2015, via certified electronic
service provider to:
Hon. Christopher M. Eaton
Guadalupe County Attorney’s Office
211 West Court Street, 3rd Floor
Seguin, Texas 78155
chris.eaton@co.guadalupe.tx.us
Hon. Susan Schoon
Zamora & Schoon, PLLC
118 S. Union Avenue
New Braunfels, Texas 78130
sschoon@zslawoffice.com
/s/ STACEY M. GOLDSTEIN
Assistant State Prosecuting Attorney