PD-0177-15
PD-0177-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
February 13, 2015 Transmitted 2/13/2015 1:36:39 PM
Accepted 2/13/2015 2:14:08 PM
ABEL ACOSTA
NO. ______________________ CLERK
ESPERANZA ESQUIVEL § 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 Esperanza Esquivel, Appellant in the above styled and
numbered cause, and moves for an extension of time of 20 days to file a petition
for discretionary review, and for good cause shows the following:
1. Counsel was court-appointed to represent the Defendant on appeal.
On January 15, 2015, the Court of Appeals affirmed appellant's conviction.
Esperanza Esquivel v. State, No. 11-12-00313-CR. This petition is therefore due
on February 14, 2015.
2. Counsel has been unable to complete the petition for the following
reasons: Counsel had a scheduled vacation during part of the briefing period. In
addition, counsel is completing another brief for a federal criminal appeal that is
due February 23, 2015.
3. Defendant is currently free on bond.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully
requests an extension of 20 days, i.e. until March 6, 2015, to file a petition for
discretionary review.
Respectfully submitted,
Damian Castillo, Attorney at Law
407 N. Big Spring, Suite 200
Midland, Texas 79701
Tel: 432-570-9979
Fax: 432-570-9918
By:/s/ Damian Castillo
Damian Castillo
State Bar No. 24056935
damian@westtexasattorney.com
Attorney for Esperanza Esquivel
CERTIFICATE OF SERVICE
This is to certify that on February 13, 2015, a true and correct copy of the
above and foregoing document was served on the District Attorney's Office,
Midland County, 500 N. Loraine, Midland, Texas 79701, by fax to 432-688-4938.
/s/ Damian Castillo
Damian Castillo
Esquivel, Esperanza
Combined Opinion