PD-1586-15
PD-1586-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/7/2015 12:00:00 AM
December 7, 2015 Accepted 12/7/2015 2:33:39 PM
No. ____________________ ABEL ACOSTA
CLERK
In The
Court of Criminal Appeals
Of The State of Texas
Austin, Texas
_________________________________________
CHRISTOPHER JOSEPH CAMPOS,
Petitioner
vs.
THE STATE OF TEXAS
_________________________________________
MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY
REVIEW
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Christopher Campos, Appellant in Cause Number 09-14-00481-CR in the
Ninth Court of Appeals- Beaumont, and asks this Court to permit the extension of time to file the
Petition for Discretionary Review, pursuant to the Texas Rules of Appellate Procedure, and for
good cause shows the following:
1. Appellant hereby requests leave of the Court to extend the time to file the Petition
for Discretionary Review. The current deadline was December 4, 2015. No previous extensions
to file the brief have been requested or granted.
2. Undersigned counsel inadvertently miscalculated the deadline to file the Petition
(or the motion to extend), and respectfully requests that the Court grant this extension and allow
counsel to file the petition on Monday, December 7, 2015, in the interest of justice for Appellant
Christopher Campos.
3. Undersigned counsel respectfully requests a 30 day extension of the deadline but
will nevertheless file the Petition for Discretionary Review on Monday, December 7, unless
instructed otherwise by the Court. .
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this
Motion for Extension of Time to File the Petition for Discretionary Review and for such other and
further relief as the Court may deem appropriate.
Respectfully submitted,
THE GERTZ LAW FIRM
2630 Liberty St.
Beaumont, Texas 77702
Tel: (409) 833-6400
Fax: (409) 833-6401
/s/ Ryan W. Gertz
By:
Ryan W. Gertz
State Bar No. 24048489
Attorney for Marcus James
CERTIFICATE OF SERVICE
This is to certify that on December 5, 2015, a true and correct copy of the foregoing
document was served on the Jefferson County District Attorney's Office, 1001 Pearl St., 3rd Floor,
Texas 77701, via e-file.
/s/ Ryan W. Gertz
Ryan W. Gertz