PD-0751-15
RECEIVED IN
NO. PD- COURl OF CRIMINAL APPEALS
IN THE JUN 19 2015
COURT OF CRIMINAL APPEALS
OF texas Ab«i Acosta, Clerk
MIGUEL RAMIREZ ) APPELLANT
v. )
THE STATE OF TEXAS ) fAbffillMeE
COURT OF uHiMNAL AHHbALS
MOTION TO EXTEND TIMETO ,., . ~ms-
FILE PETITION FORDISCRETIONARY REVIEW Joi^ i9 flMD
TO THE HONORABLE JUDGES OF SAID COURT: Auel Acosta, Clerk
Now comes Miguel Ramirez, Appellant in the above styled and numbered cause, and pursuant to
Texas Rules ofAppellate Procedure 68.2(c), movesfor an extensionof time of 30 days to file a petition for
discretionary review, and for good cause shows the following:
1. Followingremandfrom this Court,the SecondDistrictCourt ofAppeals on April 30,2015,
affirmed appellant's conviction in its opinion andjudgment in Miguel Ramirez v. The State ofTexas, Case
No. 02-14-00386-CR,(Tex.App.—Fort Worth, decided April 30, 2015);no motion for rehearing was filed
and the petition for discretionary review was therefore due on May 30, 2015.
2. Appellant requests an additional thirty (30) days from the deadline stated above and
Appellant asks this Court to order the petition to be due on or before June 29, 2015 file his Petition for
Discretionary Review.
3. No previous extensions have been requested.
4. The facts relied upon to reasonably explain the need for an extension oftime are as follows:
Appellant is considering to file a petition for discretionary review (PDR). Appellant is currently seeking
legal counsel and may not have sufficient time to prepare the PDR.
MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVffiW, Page 1
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requestsan extension of30
days, i.e. until June 29,2015, to file a petition for discretionary review.
Respectfully submitted
By:
Miguel Ramirez
2035 Sancerre Ln.
Carrollton, Texas 75007
APPELLANT
CERTIFICATE OF SERVICE
This is to certifythat on June 3,2015, a true and correctcopy of the aboveand foregoingdocument
was served upon the State of Texas by U.S. Mail addressed to the Hon. Paul Johnson, Criminal District
Attorney, Attn: Appellant Counsel, 1450 East McKinney, Denton, Texas 76209.
Miguel Ramirez
MOTION TO EXTEND TIME TO FHJE PETITION FOR DISCRETIONARY REVffiW, Page 2