Peek, Kevin Royce

PD-0600-15 PD-0600-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 5/18/2015 4:23:46 PM May 19, 2015 Accepted 5/19/2015 4:59:10 PM ABEL ACOSTA P.D. NO. CLERK KEVIN ROYCE PEEK, § IN THE COURT OF Appellant § vs. § § STATE OF TEXAS, § CRIMINAL APPEALS OF TEXAS Appellee § MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF THE COURT OF APPEALS: Comes Now, Appellant, Kevin Royce Peek, and files this Motion for Extension of Time to File Petition for Discretionary Review under Rule 68.2(c) of the Texas Rules of Appellate Procedure and would show: I. The judgment of the Eleventh Court of Appeals at Eastland, Texas was entered on April 16, 2015 in Kevin Royce Peek, Appellant, vs. The State of Texas, Appellee, Case No. 11-12-00319-CR. Said judgment upheld the trial court’s judgment below. II. No Motion for Rehearing was filed. 1 III. The deadline for filing Appellant’s Petition for Discretionary Review is May 18, 2015. No previous extensions of time to file the petition have been granted. IV. Appellant’s requests an extension of time of thirty (30) days to file his Petition for Discretionary Review until June 17, 2015 for the following reasons. 1. The undersigned attorney was preparing a brief filed on May 8, 2015 in Brandi Marie Spivey, Appellant, vs. The State of Texas, Appellee, in Case No. 11-14-00365-CR. 2. The undersigned will need more time than usual to research the potential issues for the petition for discretionary review in this case. 3. This extension of time is necessary for Appellant to receive effective assistance of counsel. PRAYER FOR RELIEF WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this motion for an extension of thirty (30) days until June 17, 2015 to file Appellant’s petition for discretionary review herein. Respectfully submitted, /s/ Connie J. Kelley Connie J. Kelley Attorney for Appellant 2 1108 Lavaca, #110-221 Austin, TX 78701 (512)445-4504 (512)478-2318 (facsimile) warrentucker@grandecom.net State Bar No. 11199600 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing was served on Michael Murray, Brown County District Attorney, at 200 S. Broadway, Brownwood, Texas 76801 on the 18th day of May, 2015, by regular mail. /s/ Connie J. Kelley Connie J. Kelley CERTIFICATE OF COMPLIANCE This is to certify that the foregoing document is in 14 point font, with the exception of footnotes, which are in 12 point font. The word count of the foregoing document is 252 words, which is in compliance with T.R.A.P. Rule 9.4. /s/ Connie J. Kelley Connie J. Kelley 3