Valdez, Osbaldo

PD-0466-15 PD-0466-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 4/23/2015 6:33:41 PM Accepted 4/24/2015 3:14:42 PM NO. _______________________ ABEL ACOSTA CLERK OSBALDO VALDEZ, § IN THE TEXAS Petitioner § § VS. § COURT OF § § THE STATE OF TEXAS, § Appellee § CRIMINAL APPEALS MOTION TO FILE PETITION FOR DISCRETIONARY REVIEW LATE TO THE HONORABLE JUDGE OF SAID COURT: Comes now Osbaldo Valdez, Petitioner, and files this motion for an extension of three (3) days to file the Petition for Discretionary Review. In Support thereof, Petitioner would show as follows: Petitioner was conviction was affirmed by the Second Court of Appeals on March 19, 2015. The deadline for filing Petitioner’s Petition for Discretionary Review was April 20, 2015. This is Petitioner’s first request for an extension of time. WHEREFORE, PREMISES CONSIDERED, counsel is requesting a three (3) days extension, until April 23, 2015, to adequately discharge his duty to his client. April 24, 2015 1 Respectfully submitted, Stickels & Associates, P.C. John W. Stickels P. O. Box 121431 Arlington, Texas 76012 Phone: (817) 479 - 9282 Fax: (817) 622 - 8071 BY: /S/ John W. Stickels John W. Stickels State Bar No. 19225300 Attorney for Osbaldo Valdez CERTIFICATE OF SERVICE I hereby certify that on the 23rd day of April, 2015, a true and correct copy of the above and foregoing Motion has been delivered to the office of the Tarrant County Criminal District Attorney, 401 West Belknap, Fort Worth, Texas 76196. /S/ John W. Stickels John W. Stickels CERTIFICATE OF CONFERENCE I hereby certify that on the 23rd day of April, 2015, a conference was held between my office and a representative for the Tarrant County District Attorney’s Office, and she stated that she is not opposed to the granting of Petitioner’s Motion for Extension of Time. /S/ John W. Stickels John W. Stickels 2