PD-0587-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/19/2015 10:31:58 AM
Accepted 6/19/2015 2:43:19 PM
No. PD-0587-15 ABEL ACOSTA
CLERK
IN THE COURT
OF CRIMINAL APPEALS OF TEXAS
ANDREW OLEVIA JONES §
§
vs. § Case No. 01-14-00501-CR
§
THE STATE OF TEXAS §
MOTION FOR LEAVE TO FILE PETITION
FOUR DAYS AFTER LAST DAY TO FILE PETITION
TO THE HONORABLE JUSTICES OF THIS COURT:
Appellant Andrew Olevia Jones moves the Court for leave to file his Petition for
Discretionary Review on June 19, 2015; the Petition is being filed simultaneously with
this motion.
1. In cause number 01-14-00501-CR, the First Court of Appeals affirmed Mr.
Jones’s conviction on April 14, 2015. The deadline to file the petition for
discretionary review was June 15, 2015. Rule 68.2(c) of the Texas Rules of
Appellate Procedure provides that the Court may extend the time to file the
petition if a motion to extend is filed no later than 15 days after the last day for
filing the petition
2. Mr. Jones has made one previous request for extension.
In view of the foregoing, Mr. Jones moves the Court to permit him to file his petition
for discretionary review until and including June 19, 2015.
June 19, 2015
Respectfully submitted,
Alexander Bunin
Chief, Harris County Public Defender’s Office
/s/ Melissa Martin
_____________________________________
Melissa Martin
Assistant Public Defender
1201 Franklin, 13th Floor
Houston, TX 77002
713/274-6709; Fax 713/437-4319
Email melissa.martin@pdo.hctx.net
Texas Bar # 24002532
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing Motion was e-served to Alan Curry,
Assistant District Attorney, Harris County Texas and to the State Prosecuting Attorney.
/s/Melissa Martin
_______________________________
MELISSA MARTIN