PD-1315-15 PD-1315-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
October 7, 2015 Transmitted 10/5/2015 3:30:30 PM
Accepted 10/7/2015 3:00:53 PM
ABEL ACOSTA
CAUSE NO. 07-13-280- CR CLERK
TERESA AGUILERA § IN THE COURT OF
§
v. § CRIMINAL APPEALS
§
STATE OF TEXAS § OF TEXAS
MOTION TO EXTEND THE TIME TO FILE THE
PDR CONTEMPORANEOUSLY SUBMITTED
WITH THIS MOTION
TO THE HONORABLE JUDGES OF THE
COURT OF CRIMINAL APPEALS:
COMES NOW Teresa Aguilera, Petitioner, and files this motion to extend
the time to file the PDR to October 5, 2015, the date of its e-filing.
I.
The court of appeals’ ruling was issued on July 30, 2015, and the order
denying rehearing on September 1, 2015, making the PDR due October 1, 2015.
No prior extension motion has been filed.
II.
The reason for this request is as follows. On September 29, 2015,
undersigned counsel has very recently finished and filed a very long and involved
opening brief in Martin v. State, 07-15-00079-CR, and until now has not had time
to prepare the PDR.
WHEREFORE, the Petitioner prays the Court grant an extension of time to
file her PDR to October 5, 2015, the date the PDR is electronically filed.
Respectfully submitted,
/s JOHN BENNETT
John Bennett
Post Office Box 19144
Amarillo, Texas 79114
(806) 282-4455
Fax: (806) 398-1988
State Bar Number 00785691
Email: AppealsAttorney@gmail.com
Attorney for the petitioner
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above Motion has been served on
Richard Martindale, Esq., by personal delivery, and on Lisa McMinn, Esq., State
Prosecuting Attorney, by email to her at lisa.mcminn@spa.texas.gov, both on
October 5, 2015.
/s JOHN BENNETT
John Bennett
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