PD-0986-15
PD-0986-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/31/2015 12:34:00 PM
July 31, 2015 Accepted 7/31/2015 3:14:51 PM
ABEL ACOSTA
No. ___________ CLERK
In the
COURT OF CRIMINAL APPEALS
______________________________________
On Appeal from the 272nd Judicial District Court of
Brazos County, Texas
Cause Number 09-03781-CRF-272; and the
Opinion of the Tenth Court of Appeals
in Cause Number 10-14-00227-CR, Delivered July 31, 2015
______________________________________
PEDRO RODRIGUEZ, 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
Pedro Rodriguez, 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 August 29, 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 October 29, 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 August 29,
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 petition for
discretionary review in this case will now be due on October 29, 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 emailed to Doug
Howell, Attorney of the Record for the Brazos County District Attorney’s Office
on July 31, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
2