Wall, Lisa D.

PD-0693-15 PD-0693-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 6/5/2015 9:16:28 AM Accepted 6/8/2015 3:00:17 PM IN THE ABEL ACOSTA CLERK COURT OF CRIMINAL APPEALS LISA D. WALL, § APPELLANT § § V. § NO. 02-13-00552-CR § THE STATE OF TEXAS, § APPELLEE § LISA D. WALL’S MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW COMES NOW Lisa D. Wall, by and through her attorney, and files this motion to extend the time for 30 days to file a petition for discretionary review. I. The court of appeals below is the Court of Appeals for the Second District of Texas. The style and number of the case in the Second District Court of Appeals is Wall v. State, No. 02-13- 00552-CR. II. On May 7, 2015, the Fort Worth Court of Appeals issued a memorandum opinion affirming the trial court’s judgment. See Wall v. State, No. 02-13-00552-CR, 2015 WL 2169307 (Tex. App. —Fort Worth May 7, 2015). Appellant did not file a motion for rehearing. III. June 8, 2015 The current filing deadline for filing Appellant’s petition for discretionary review is June 6, 2015. Wall now requests an extension of 30 days, until July 6, 2015, to file Appellant’s petition. In this case, Appellant has not previously requested an extension of time to file a petition for discretionary review. IV. This extension is not for the purpose of delay, but rather so that the undersigned counsel may adequately set forth Appellant’s argument on her grounds for review. The undersigned attorney has been working on this petition for discretionary review, preparing several other cases for trial, preparing another case for appeal, and will be out of the country from June 15, 2015 – June 21, 2015. Appellant prays that this Court grant a 30-day extension until July 6, 2015 to file Appellant’s petition for discretionary review. THE ZENDEH DEL LAW FIRM, PLLC By: _________________________________ Jason A. Zendeh Del 7600 San Jacinto Place, Suite 200 Plano, TX 75024 Tel: (214) 919-3600 Fax: (214) 919-3599 State Bar No. 24044988 Jason@zenlawfirm.com Attorney for Lisa D. Wall CERTIFICATE OF CONFERENCE Undersigned counsel certifies that he conferred with the Denton County District Attorneys’ Office regarding the extension of thirty days, and Denton County District Attorneys’ Office does not oppose the extension. _________________________________ Jason A. Zendeh Del CERTIFICATE OF SERVICE A copy of Appellant’s Motion to Extend Time to File Petition for Discretionary Review has been served to the State of Texas, Denton County Criminal District Attorney, Attn: Appellate Division, vi fax to (940) 349-2601, on the dame date as filing. _________________________________ Jason A. Zendeh Del