PD-0063-15
PD-0063-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 1/15/2015 10:28:43 PM
Accepted 1/21/2015 3:44:09 PM
TO THE COURT OF CRIMINAL APPEALS OF TEXAS ABEL ACOSTA
CLERK
No.____________
_________________________________
RAYMOND BUCHANAN,
Appellant
v.
THE STATE OF TEXAS,
Appellee
_________________________________
MOTION TO EXTEND TIME TO FILE PETITION
FOR DISCRETIONARY REVIEW
_________________________________________________________
On Petition for Discretionary Review from the Court of Appeals for
the First District, Houston, Texas in Cause No. 01-13-00954-CR,
Affirming an appeal from a judgment issued in Cause No. 68872 from
the 300th District Court of Brazoria County, Texas.
_________________________________________________________
R. Scott Shearer
TBA No. 00786464
929 Preston, Suite 200
Houston, TX 77002
January 21, 2015 (713) 254-5629
(713) 224-2889 FAX
ShearerLegal@Yahoo.com
Attorney for Appellant
January 15, 2014
TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS:
NOW COMES, RAYMOND BUCHANAN, and files this Motion To Extend
Time To File Petition For Discretionary Review. In support of this motion, he would
respectfully show the Court the following:
I.
In an UNPUBLISHED opinion delivered December 16, 2014, a panel of the First
Court of Appeals AFFIRMED Appellant’s appeal from a judgment of conviction for sexual
abuse of a child by the 300th District Court of Brazoria County. Appellant did not file a
motion for rehearing. Appellant’s Petition for Discretionary Review is due on January 16,
2014. This motion to extend time to file petition for discretionary review is timely filed
within thirty days after the court of appeals issued its opinion or overruled Appellant’s
Motion for Rehearing or within fifteen days of said deadline. See TEX. R. APP. PROC. 68.2.
II.
Appellant is requesting additional time to file the petition for discretionary review.
More time is necessary to research the issues involved.
III.
Appellant asserts that this motion is not made solely for purposes of delay and that
the granting of this motion will not prejudice the rights of the State.
IV.
Appellant is therefore requesting a thirty [30] day extension so that his Petition may
be timely filed.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the
Honorable Court of Criminal Appeals will grant his Motion To Extend Time To File
Petition For Discretionary Review.
Respectfully submitted,
/s/R. SCOTT SHEARER
R. Scott Shearer
TBA No. 00786464
929 Preston, Suite 200
Houston, TX 77002
(713) 254-5629
(713) 224-2889 FAX
ShearerLegal@Yahoo.com
Attorney for Appellant
January 15, 2014
CERTIFICATE OF SERVICE
I certify that a copy of this Motion has been served upon the State of Texas by e-
mailing a copy of same to the following parties at the following addresses on this the 15th
day of January, 2014:
JERI YENNE.
BRAZORIA COUNTY DISTRICT ATTORNEY
111 E. LOCUST, SUITE 408A
ANGLETON, TX 77515
DEBRAP@BRAZORIA-COUNTY.COM
/s/R. SCOTT SHEARER
R. Scott Shearer