PD-0797-15
PD-0797-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/29/2015 11:42:35 AM
Accepted 6/29/2015 5:03:19 PM
NO. ________________ ABEL ACOSTA
CLERK
IN THE COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
________________________________________________________
ARTURO CHAVEZ
Petitioner,
V.
THE STATE OF TEXAS
Respondent.
_________________________________________________________
On Appeal from the 338th Judicial District Court of Harris
County, Texas - Trial Court No. 1338052
Appeal No. 01-14-00232-CR
_________________________________________________________
MOTION FOR EXTENSION OF TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
__________________________________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
Arturo Chavez, Appellant, moves this Court for a thirty-day extension of time to file his
petition for discretionary review. The court of appeals issued its opinion on May 28, 2015, making
a petition due on June 29, 2015. Counsel has been unable to complete a petition by the deadline
due to numerous conflicts in his schedule. The matter that has consumed much of counsel’s time
in the last thirty days is United State v. Robert Durst, No, 15-CR-091, In the United States District
Court, for the Eastern District of Louisiana, New Orleans, Louisiana. Counsel was responsible for
researching and drafting pretrial motions in that complex case. Counsel requests an additional
thirty days to prepare a petition on Appellant’s behalf.
June 29, 2015
Respectfully submitted,
DeGUERIN, DICKSON, HENNESSY & WARD
/s/Matt Hennessy
Matt Hennessy
State Bar No. 00787677
1018 Preston, 7th Floor
Houston, Texas 77002
(713 223-5959 Telephone
(713) 223-9231 Facsimile
matt@deguerin.com
Attorney for Petitioner
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the foregoing Motion for Extension of Time
to File Petition for Discretionary Review has been delivered to all interested parties, via electronic
filing, on June 29, 2015.
/s/Matt Hennessy
Matt Hennessy