PD-0793-15 PD-0793-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
June 29, 2015 Transmitted 6/26/2015 1:04:12 PM
Accepted 6/29/2015 3:14:29 PM
ABEL ACOSTA
PD ______________ CLERK
IN THE COURT OF CRIMINAL APPEALS
___________________________________________________
MITCHELL DEAN COCHRAN
VS.
THE STATE OF TEXAS
___________________________________________________
MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR
DISCRETIONARY REVIEW
____________________________________________________
TO THE HONORABLE JUDGES OF SAID COURT:
I.
COMES NOW, Appellant in the above styled case, and makes and
files this his request for an extension of time to file his PDR and would show
unto the Court the following:
COURT BELOW: Tenth Court of Appeals
CAUSE NUMBER BELOW: NO. 10-14-00013-CR
DATE FOR PETITION OF
DISCRETIONARY REVIEW REFUSED: None
PRESENT DEADLINE FOR
FILING APPELLANTS’ PDR: 6-26-15
Mitchel Dean Cochran 1
DAYS REQUESTED BY THIS
EXTENSION: 30
DATE TO WHICH EXTENSION
IS REQUESTED: 7-26-15
NUMBER OF EXTENSIONS
PREVIOUSLY GRANTED: None
I.
The Appellee’s request is based upon the following reasonable
explanation of the need for additional time, within the personal knowledge
of Charles W. McDonald, the attorney signing this motion, T.R.A.P. 10.5(b),
namely:
II.
Counsel’s daughter was hospitalized under emergency conditions on
June 4, 2015, requiring a week-long trip to Los Angeles. Counsel’s father
passed away unexpectedly in a car wreck on June 11, 2015.
III.
WHEREFORE, this Attorney for the Appellant prays that the Court
grant this motion and extend the time and deadline for the filing of
Appellant’s brief, or the Court grant such additional time as is just and
proper.
Respectfully submitted,
/s/________________________
Charles W. McDonald
ATTORNEY AT LAW
2024 Austin Avenue
Waco, Texas 76701
(254) 752-9901
FAX: (254) 754-1466
SBOT NO. 13538800
Mitchel Dean Cochran 2
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the above and
foregoing instrument was served upon Abelino “Abel” Reyna, McLennan
County Criminal District Attorney, 219 N. Sixth Street, Suite 200, Waco,
Texas 76701-1363, according to rule and law, this 26th day of June, 2015.
/s/___________________________
Charles W. McDonald
Mitchel Dean Cochran 3