Andrews, Julia Rhoton

FILED IN PD-0052-15
COURT OF\CRIMINAL APPEALS _^__^ ..„' , COURT OF CRIMINAL APPEALS
~ ( PD-0052-15 AUSTIN, TEXAS
JANUARY 20,2015 \J\J~>** J-^ Transmitted 1/13/2015 1:10:01 PM
Accepted 1/20/2015 5:22:50 PM
ABEL ACOSTA, CLERK NO. ———————_______
ABEL A~?f2A
GLfcKtS

JULIA RHOTON ANDREWS § 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 Julia Rhoton Andrews, Appellant in the above styled and

numbered cause, and moves for an extension of time of 30 days to file a

petition for discretionary review, and for good cause shows the following:

1. On [December 10, 2014, the Court of Appeals affirmed

appellant's conviction. Julia Rhoton Andrews v. State, 09-13-00407-CR.

This petition is therefore due on January 10, 2015.

2. Counsel has been unable to complete the petition for the

following reasons: Counsel for Appellant has been laboring under a heavy

caseload and requires more time to prepare said brief and requests more

time to file said PDR.

3. Defendant is currently incarcerated.

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WHEREFORE, PREMISES CONSIDERED, appellant respectfully

requests an extension of 30 days, i.e. until February 11, 2015, to file a

petition for discretionary review.

Respectfully submitted,

CHRISTINE R BROWN-ZETO
Attorney at Law
1107 Green Avenue
Orange, Texas 77630
Tel: (409) 886-8558
Fax: (409) 883-6523

By: /S/ Christine R. Brown-Zeto
Christine R. Brown-Zeto
State Bar No. 03102200
crbrown@exp.net
Attorney for Julia Rhoton Andrews

CERTIFICATE OF SERVICE

This is to certify that on January 12, 2015, a true and correct copy of

the above and foregoing document was served on the District Attorney's

Office, Orange County, 801 Division, Orange, Texas 77630, by mail.

ISI Christine R. Brown-Zeto
Christine R. Brown-Zeto

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