PD-1125-15
PD-1125-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/28/2015 4:44:54 PM
Accepted 9/1/2015 9:57:48 AM
ABEL ACOSTA
CLERK
IN THE COURT OF CRIMINAL APPEALS OF TEXAS
GEOFFREY KEVIN PITCOCK
September 1, 2015
VS.
THE STATE OF TEXAS
FROM THE ELEVENTH COURT OF APPEALS
EASTLAND
NO. 11-13-00213-CR
APPEALED FROM TARRANT COUNTY CRIMINAL COURT THREE
TARRANT COUNTY, TEXAS
TRIAL NUMBER 1170491
MOTION TO EXTEND TIME OF FILING OF PETITION FOR DISCRETIONARY
REVIEW TO THE COURT OF CRIMINAL APPEALS.
This motion is brought by the Applicant GEOFFREY KEVIN PITCOCK, who
moves the Court to permit him to file this Application late and would show the Court
the following:
I
The opinion of the Court of Appeals is dated July 30, 2015. The correct
statutory time for filing a Petition for Discretionary Review is within 30 days, August
28, 2015.
This motion is brought within 15 days of August 28, 2015.
II.
The attorney for the applicant has within the last 45 days served as chief
counsel in two felony and several misdemeanor jury trials. The time and effort in the
preparation of the aforementioned jury trials caused the counsel for the Applicant to
not file the Petition for Discretionary Review within the 30 days. As a result of the
aforementioned activities counsel for Appellant, reasonably believes that the
Petitioner for Discretionary Review will be filed with this Court within thirty (30) days
of the August 28, 2015, date.
The granting of this motion should not delay any action that would otherwise
take place.
WHEREFORE PREMISES CONSIDERED, Applicant prays that this Court
grant this request to file the Petition for Discretionary Review.
Respectfully submitted,
/s/ Abe Factor_____________________
Abe Factor
Attorney for Appellant
State Bar No. 06768500
FACTOR & CAMPBELL
5719 Airport Freeway
Fort Worth, TX 76117
(817) 222-3333
(817) 222-3330 (fax)
lawfactor@yahoo.com
CERTIFICATE OF SERVICE
I, ABE FACTOR, DO HEREBY CERTIFY THAT A TRUE AND CORRECT
COPY OF THE ABOVE AND FOREGOING INSTRUMENT HAS BEEN DELIVERED
TO THE ATTORNEY FOR THE STATE AND TO THE STATE PROSECUTING
ATTORNEY AUSTIN, TEXAS.
On this the 28th day of August, 2015.
/s/ Abe Factor_____________________
Abe Factor