PD-0659-15
PD-0659-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/29/2015 12:21:46 PM
June 1, 2015 Accepted 6/1/2015 2:29:26 PM
NO. ______________ ABEL ACOSTA
CLERK
IN THE
COURT OF CRIMINAL APPEALS
OF TEXAS
PAUL HENRI WAGNER ) APPELLANT
v. )
THE STATE OF TEXAS ) APPELLEE
MOTION TO EXTEND TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
Now comes, Paul Henri Wagner, Appellant in the above styled and numbered cause, by
and through his attorneys of record, Vincent W. Perini and Dan Wood, Jr., and pursuant to Texas
Rules of Appellate Procedure 68.2(c), moves for an extension of time of 30 days to file a petition
for discretionary review, and for good cause shows the following:
1. The Court of Appeals below affirmed appellant’s conviction in its opinion and
judgment in Paul Henri Wagner v. The State of Texas, Case No. 05-13-01329-CR, (Tex.App. –
Dallas, decided May 5, 2015); no motion for rehearing was filed and the petition for
discretionary review is therefore due on June 4, 2015.
2. Appellant requests an additional forty-five (45) days from the deadline stated
above and Appellant asks this Court to order the petition to be due on or before July 19, 2015.
3. No previous extensions have been requested.
4. The facts relied upon to reasonably explain the need for an extension of time are
as follows: On May 28, 2015, Dan Wood, Jr., became associated as co-counsel to represent
Appellant in regarding a petition for discretionary review. New counsel needs additional time to
MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW, Page 1
read the record and research grounds for the petition. Appellant does wish to pursue his right to
file a petition for discretionary review and requests this court to allow additional time for new
counsel to adequately prepare same
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests an
extension of 45 days, i.e. until July 19, 2015, to file a petition for discretionary review.
Respectfully submitted,
VINCENT W. PERINI
DAN WOOD, JR
ATTORNEY AT LAW
4303 N. Central Expressway
Dallas, TX 75205
(214) 559-8815 Office tel.
(214) 696-0867 Fax
/Dan Wood, Jr./
By:
Dan Wood, Jr.
State Bar No. 21887050
Email: danwoodjr@sbcglobal.net
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
This is to certify that on May 29, 2015, a true and correct copy of the above and
foregoing document was served upon the State of Texas by U.S. Mail addressed to: Hon. Susan
Hawk, Criminal District Attorney, Attn: Appellant Division, 133 N. Riverfront Blvd., LB 19,
Dallas, TX 75207.
/Dan Wood, Jr./
Dan Wood, Jr.
MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW, Page 2