PD-1080-15
PD-1080-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/18/2015 11:15:09 PM
Accepted 8/20/2015 11:52:27 AM
ABEL ACOSTA
CLERK
NO. _______________
IN THE COURT OF CRIMINAL APPEALS
STEVE ACOSTA
August 20, 2015 Appellant,
vs.
THE STATE OF TEXAS,
Appellee
On Appeal from the 5th District Court of Appeals
Dallas, Texas
APPELLANT’S MOTION FOR EXTENSTION OF TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
Comes Now, STEVE ACOSTA, Appellant/Petitioner who hereby files this
First Motion for Extension of Time to File Petition for Discretionary Review
under Tex. R. App. P. 68.2. In support of this motion, per Tex. R. App. P.
10.5, Petitioner shows the following:
1. The Court of Appeals for the 5th Appellate District in Dallas,
TX, rendered its opinion and judgment in Steve Acosta v. State of Texas,
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Trial Court Cause No. F-1355987-M, Appellate Cause No. 05-13-01640-CR on
July 7, 2015. The Petition for Discretionary Review is due no later than
August 6, 2015. Counsel requests this extension prior to 15 days from
August 6, 2015.
2. Petitioner requests an extension of time of thirty days, to
September 7, 2015. This is Petitioner’s first request for an extension of time
in this case.
3. Petitioner relies on the following facts as a reasonable
explanation for the requested extension of time: Counsel is involved in
numerous Federal and State appeals and trials involving complex issues and
extensive transcripts. Counsel must review 1200 pages of transcripts in one
appeal and 4 terabytes of information on a trial matter. Both are set in the
next month.
WHEREFORE PREMISES CONSIDERED, Petitioner prays that
this Court grant this Motion for Extension of Time.
Respectfully submitted,
/s/ Bruce Kaye
Bruce Kaye
TBN 00784374
2309 Boll St.
Dallas, TX 75204
(214) 722-7438 Office
(866) 649-8757 Fax
Bruce@Brucekaye.com
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