PD-0793-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/27/2015 5:59:43 PM
Accepted 7/29/2015 10:55:37 AM
ABEL ACOSTA
PD 0793-15 CLERK
IN THE COURT OF CRIMINAL APPEALS
FILED IN MITCHELL DEAN COCHRAN
COURT OF CRIMINALAPPEALS
VS.
July 29, 2015
ABEL ACOSTA, CLERK 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: 7-27-15
Mitchel Dean Cochran
DAYS REQUESTED BY THIS
EXTENSION: 14
DATE TO WHICH EXTENSION
IS REQUESTED: 8-10-15
NUMBER OF EXTENSIONS
PREVIOUSLY GRANTED: 1
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 has experienced unexpected complications with his recently
deceased father's estate and the cessation of his law practice. These will be
resolved very soon.
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 PDR for 2 weeks, 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
SBOTNO. 13538800
Mitchel Dean Cochran
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 27th day of July, 2015.
/s/
Charles W. McDonald
Mitchel Dean Cochran