PD-0119-15
PD-0119-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
February 4, 2015 Transmitted 1/30/2015 1:51:10 PM
Accepted 2/4/2015 10:09:06 AM
PD-_____________ ABEL ACOSTA
CLERK
JESUS GONZALEZ X IN THE COURT OF CRIMINAL APPEALS
X
X
VS. X
X
X
THE STATE OF TEXAS X OF THE STATE OF TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
COMES NOW, JESUS GONZALEZ, Appellant, and moves that he be granted a
thirty (30) day extension of time to file his Petition for Discretionary Review in the
above-styled and numbered cause, until and including February 18, 2015, and further
shows as follows:
A. The Appellant’s conviction for intoxication manslaughter was affirmed by the
First Court of Appeals on December 18, 2014, in cause number 01-12-01115-CR;
B. The original deadline for filing the Appellant’s P.D.R. in this cause was
January 18, 2015, which made it due on January 20, 2015;
C. A request is hereby made for an extension of time to file the Appellant’s
P.D.R., until and including February 18, 2015;
D. The reason for this extension request is that the undersigned attorney has been
extremely busy with other appeals and various other matters which have left him unable
to finish the PDR on time, including, but not limited to, the following:
1) Alfred Rodriguez, Jr. v. The State of Texas; No. 01-14-00394-CR; Appellant’s
brief due February 2, 2015;
2) Khalon Westbrooks v. The State of Texas; Nos. 14-14-00499-CR &14-14-
00500-CR; Appellant’s brief due February 2, 2015;
3) William Horhn v. State of Texas; Nos. 01-14-00738-CR & 01-14-00739-CR;
Appellant’s brief due February 2, 2015;
4) Jose Vasquez v. State of Texas; No. 14-12-00096-CR; Response to a State’s
Petition for Discretionary Review due February 5, 2015;
5) Joseph Jackson v. State of Texas; No. 14-15-00017-Cr; Appellant’s brief due
February 25, 2015.
E. No previous extensions have been granted. If this extension is granted, the PDR
will be filed by February 18, 2015, and no further extensions will be required.
WHEREFORE, PREMISES CONSIDERED, Appellant moves that the Court
extend the deadline for filing the Appellant’s Petition for Discretionary Review in this
case until and including February 18, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s Mark Kratovil
MARK C. KRATOVIL
Assistant Public Defender
Harris County Texas
1201 Franklin, 13th Floor
Houston Texas 77002
(713)274-6728
TBA No. 24076098
CERTIFICATE OF SERVICE
A true copy of this motion has been hand delivered to the appellate division of the
Harris County District Attorney’s Office on January 30, 2015.
/s Mark Kratovil
MARK C. KRATOVIL