PD-0791-15
PD-0791-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/25/2015 1:59:00 PM
June 29, 2015 Accepted 6/29/2015 2:16:04 PM
ABEL ACOSTA
No. ___________ CLERK
In the
COURT OF CRIMINAL APPEALS
______________________________________
On Appeal from the 264th Judicial District Court of
Bell County, Texas
Cause Number 67109; and the Opinion of the Third Court of Appeals
in Cause Number 03-14-00381-CR, Delivered June 24, 2015
______________________________________
ERIC ALAN MOORE, JR.
v.
THE STATE OF TEXAS
_____________________________________
MOTION FOR EXTENSION OF TIME TO FILE
PRO SE PETITION FOR DISCRETIONARY REVIEW
______________________________
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL
APPEALS:
COMES NOW, Kristen Jernigan, the undersigned attorney of record for Eric
Alan Moore, Jr., the Appellant, herein, and files this Motion for Extension of Time
to File Pro Se Petition for Discretionary Review. As set out below, the undersigned
respectfully requests a sixty-day extension so that Appellant can file his Pro Se
Petition for Discretionary Review. In support of said motion, the undersigned
would show the Court the following:
1. Appellant’s Petition for Discretionary Review is currently due in this
case on July 24, 2015.
2. Appellant seeks an extension of sixty days in which to file his Petition
for Discretionary Review, making his Petition due on or before September 22,
2015.
3. The undersigned counsel will not be representing Appellant after the
filing of this motion. Appellant will now have to obtain and review the record in
order to prepare and file a Pro Se Petition for Discretionary Review. The
undersigned believes that there is insufficient time between now and July 24, 2015,
to accomplish those goals. Consequently, the undersigned respectfully requests
that the Court grant Appellant the additional time.
4. The undersigned has not filed any previous motions for extension of
time in this case.
5. For the reasons set forth above, the undersigned respectfully requests
that Appellant be granted an extension of sixty days so that his brief in this case
will now be due on September 22, 2015.
PRAYER
WHEREFORE, PREMISES CONSIDERED, the undersigned
respectfully requests that this Court grant this Motion for Extension of Time to File
Pro Se Petition for Discretionary Review.
Respectfully submitted,
_______/s/__Kristen Jernigan______
KRISTEN JERNIGAN
State Bar Number 90001898
207 S. Austin Ave.
Georgetown, Texas 78626
(512) 904-0123
(512) 931-3650 (fax)
Kristen@txcrimapp.com
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the
foregoing Appellant’s Motion for Extension of Time has been mailed to the Bell
County District Attorney’s Office, 1200 Huey Road, Belton, Texas 76513, on May
15, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
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