PD-1189-14
FILED IN COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
COURT OF CRIMINALAPPEALS
Transmitted 9/30/2015 6:22:55 PM
Accepted 10/1/2015 9:10:04 AM
October 1,2015 No. PD-1189-14 ABEL ACOSTA
r CLERK
ABELACOSTA, CLERK In The
Court of Criminal Appeals
Of The State of Texas $>
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Austin, Texas
FRANCHESKA V. JAGANATHAN,
Appellant
vs.
THE STATE OF TEXAS
MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Francheska Jaganathan, Appellant in Cause Number No. PD-1189-14 before
this Court, and asks this Court to permit the extension of time to file her Motion for Rehearing,
pursuant to Texas Rule of Appellate Procedure 79.6, and for good cause shows the following:
1. Appellant hereby requests leave of the Court to extend the time to file the Motion
for Rehearing. The current deadline is October 1, 2015. No previous extensions to file the Motion
for Rehearing have been requested or granted.
2. Undersigned counsel was preparing for trial in an attempted capital murder case
that was set for trial this week before being continued at the last minute. Undersigned counsel has
spent significant time preparing for this trial and is unable to complete the Motion for Rehearing in
the above matter by the deadline.
3. Additionally, counsel was in felony trial in Jefferson County District Court during
most of the week of September 14, 2015. These two previous engagements in addition to
ELECTRONIC
RECORD
numerous unexpected engagements this week detracted a significant amount of time from
preparing the Motion.
4. Undersigned counsel respectfully requests a 15 day extension of the deadline.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this
Motion for Extension of Time to File the Motion for Rehearing 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
Isi Ryan W. Gertz
By:
Ryan W. Gertz
State Bar No. 24048489
Attorney for Francheska Jaganathan
CERTIFICATE OF SERVICE
This is to certify that on September 30, 2015, a true and correct copy of the above and
foregoing document was served on the following by facsimile:
Chambers County District Attorney's Office
404 Washington St.
Anahuac, TX 77514
Via Facsimile - (409) 267-4453