PD-0684-15
PD-0684-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/4/2015 9:49:48 AM
Accepted 6/4/2015 12:09:03 PM
ABEL ACOSTA
CAUSE NO. CLERK
IN THE COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
STATE OF TEXAS, Appellant
June 4, 2015 V.
JOE LOUIS TIENDA, Appellee
Petition for Discretionary Review from
the Eleventh Court of Appeals
Cause No. 11-11-00283-CR and
Appeal From the 428™ Judicial District Court
Cause No. CR-07-0802
Hays County, Texas
STATE'S FIRST MOTION FOR EXTENSION OF TIME IN WHICH
TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF THE TEXAS COURT OF
CRIMINAL APPEALS:
The State files this First Motion for Extension of Time in Which to File
the State's Petitionfor Discretionary Review, and in support states:
1. The Eleventh Court Of Appeals rendered judgment in the styled
case no. 11-11-00283-CR on May 14, 2015.
2. The State's current deadline for filing her petition is June 15,
2015.
3. This is the State's first motion for extension of time in which to
file her petition.
4. The State respectfully requests an extension of approximately
thirty days, until July 15, 2015 in which to file her petition.
5. Good cause exists for the State's request for extension of time.
The Hays County District Attorney Office Civil Division has undergone
major changes in the past months. The undersigned attorney recently assumed
full time duties as an attorney for the Department of Family and Protective
Services within the District Attorney's office.
6. This extension is not being sought to cause undue delay, but to
seek justice.
7. For the foregoing reasons, the State respectfully requests that the
Court grant an approximate fifteen day extension for filing the State's
Petition for Discretionary Review, until July 15, 2015.
ctfully submitted,
)berts-Huckaby
Assistant Criminal District Attorney
Hays County, Texas
Hays County Government center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas 78666
angie.roberts@co.hays.tx.us
(512)393-7600
(512) 393-2246 fax
State Bar No. 24081797
Verification
The foregoing Appellant Motion for Extension of Time in Which to
File Petition for Discretionary Review was subscribed and sworn to before
me by Angie D. Roberts-Huckaby on this the 15th day of June 2015.
Angie D. Roberts-Huckaby
RHONDA WIEDERSTEIN
my COMMISSION EXPIRE'-
September 9.2018
Notary Public tate of Texas
CERTIFICATE OF SERVICE
I certify that on June 15, 2015, I served the above motion by email to
Mr. Chevo Pastrano at chevo@pastranolaw.com, in accordance with the
Texas Rules of ApzfEK^ate Procedure.
ngiel). Roberts-Huckaby
Tienda, Joe Louis
Combined Opinion