PD-0189-15
PD-0189-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 2/17/2015 5:09:37 PM
February 19, 2015 Accepted 2/19/2015 1:07:01 PM
ABEL ACOSTA
No. ___________ CLERK
In the
COURT OF CRIMINAL APPEALS
______________________________________
On Appeal from the 272nd Judicial District Court of
Brazos County, Texas
Cause Number 12-03436-CRF-272; and the Opinion of the Tenth Court of Appeals
in Cause Number 10-13-00429-CR, Delivered February 12, 2015
______________________________________
DANIEL PAUL CAMPBELL
v.
THE STATE OF TEXAS
_____________________________________
MOTION FOR EXTENSION OF TIME TO FILE
PRO SE PETITION FOR DISCRETIONARY REVIEW
______________________________
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL
APPEALS:
COMES NOW, Kristen Jernigan, the undersigned attorney of record for
Daniel Paul Campbell, the Appellant, herein, and files this Motion for Extension of
Time to File Pro Se Petition for Discretionary Review. As set out below, the
undersigned respectfully requests a sixty-day extension so that Appellant can file
his Pro Se Petition for Discretionary Review. In support of said motion, the
undersigned would show the Court the following:
1. Appellant’s Petition for Discretionary Review is currently due in this
case on March 14, 2015.
2. Appellant seeks an extension of sixty days in which to file his Petition
for Discretionary Review, making his Petition due on or before May 13, 2015.
3. The undersigned counsel will not be representing Appellant after the
filing of this motion. Appellant will now have to obtain and review the record in
order to prepare and file a Pro Se Petition for Discretionary Review. The
undersigned believes that there is insufficient time between now and March 14,
2015, to accomplish those goals. Consequently, the undersigned respectfully
requests that the Court grant Appellant the additional time.
4. The undersigned has not filed any previous motions for extension of
time in this case.
5. For the reasons set forth above, the undersigned respectfully requests
that Appellant be granted an extension of sixty days so that his brief in this case
will now be due on May 13, 2015.
PRAYER
WHEREFORE, PREMISES CONSIDERED, the undersigned
respectfully requests that this Court grant this Motion for Extension of Time to File
Pro Se Petition for Discretionary Review.
Respectfully submitted,
_______/s/__Kristen Jernigan______
KRISTEN JERNIGAN
State Bar Number 90001898
207 S. Austin Ave.
Georgetown, Texas 78626
(512) 904-0123
(512) 931-3650 (fax)
Kristen@txcrimapp.com
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the
foregoing Appellant’s Motion for Extension of Time has been mailed to the Brazos
County District Attorney’s 300 E. 26th Street, Bryan, Texas 77803 on February 17,
2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
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