PD-0237-15
PD-0237-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 3/2/2015 11:03:32 AM
Accepted 3/2/2015 3:01:09 PM
ABEL ACOSTA
NO._________________
CLERK
IN THE
COURT OF CRIMINAL APPEALS
OF TEXAS
RHONALD MARTINEZ
Petitioner
March 2, 2015 v.
THE STATE OF TEXAS
Respondent
Petition is in Cause No. 1253416D from the
297th Criminal District Court of Tarrant County, Texas,
and Cause No. 02-13-00610-CR in the
Court of Appeals for the Second District of Texas
MOTION TO EXTEND TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF APPEALS:
COMES NOW, Rhonald Martinez, Petitioner, and requests that this Court
grant an extension of time for filing of Petitioner’s Petition for Discretionary Review,
and in support of which would show the following:
I.
Petitioner’s Petition for Discretionary Review is due on or before March 2,
2015. The time for extension requested is thirty (30) days.
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II.
Because of an unusually heavy caseload consisting of both jury trials as well
as other appellate obligations, counsel for Petitioner has been unable to complete
said Petition; as a result of trial preparation and actual trial, counsel for Petitioner
has been unable to devote a sufficient amount of time to the preparation of said
Petition.
Counsel for Petitioner reasonably believes that the Petitioner for Discretionary
Review will be filed with this Court within 30 (30) days of the March 2, 2015, due
date.
III.
No previous “Motion to Extend Time to File Petition for Discretionary
Review” has been granted or requested.
IV.
The Petitioner is incarcerated.
WHEREFORE, PREMISES CONSIDERED, Rhonald Martinez, Petitioner,
prays this Court will grant an extension of thirty (30) days for Petitioner to file said
Petition for Discretionary Review.
Respectfully submitted,
/s/Abe Factor
Abe Factor
TBN: 06768500
Factor, Campbell & Collins
Attorneys at Law
5719 Airport Freeway
Fort Worth, Texas 76117
Phone: (817) 222-3333
Fax: (817) 222-3330
Attorney for Appellant
Rhonald Martinez
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument has
been
furnished to counsel for the State’s Prosecuting Attorney and the Tarrant County
District Attorney by a manner compliant with the Texas Rules of Appellate
Procedure,
on this 2nd day of March, 2015.
/s/Abe Factor
Abe Factor
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