PD-1640-15
PD-1640-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/17/2015 3:05:36 PM
Accepted 12/19/2015 9:41:55 AM
ABEL ACOSTA
Appellate No. 09-14-00062-CR CLERK
MARC RICHARD SAUNDERS § IN THE TEXAS COURT OF
§ CRIMINAL APPEALS
§
VS. §
§
STATE OF TEXAS §
MOTION TO EXTEND TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes MARC RICHARD SAUNDERS, Appellant in the above styled and
numbered cause, and moves this Court to grant an extension of time to file
appellant's Petition for Discretionary Review and for good cause shows the
following:
1. This case is on appeal from the Ninth District Court of Appeals in
Beaumont, styled MARC RICHARD SAUNDERS vs. STATE OF TEXAS
and was given Appellate No. 09-14-00062-CR.
2. The Court of Appeals' judgment was signed November 18, 2015.
3. The deadline to file Petition for Discretionary Review is December
18, 2015.
December 18, 2015
Saunders' Motion to Extend Time to File PDR 1 of 3
4. Appellant requests an extension of time until January 18, 2016 or
a time period of at least 30 days.
5. Appellant has not requested any prior extensions regarding
petition for discretionary review.
6. Appellant relies on the following facts as good cause for the
requested extension:
Counsel is a solo practitioner and has been involved in or prepared for the
following criminal trials, appeals or motions:
(i) Montgomery County, State of Texas v. Mike Angel Ulloa,
221st District Court, 14-02-02317-CR, Tampering; Writ of
Habeas Corpus Appeal, Beaumont Court of Appeals, 9th
District, 09-15-00398-CR
(ii) United States District Court Southern District of Texas,
United States v. Darnell Menard, 15cr296-01 , Judge Atlas
Houston, Conspiracy, and multiple counts of fraud related
activity under 18 USC 1029(a)(2);(a)(3); and (b)(2).
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court
grant this Motion To Extend Time to File Petition for Discretionary Review, and
for such other and further relief as the Court may deem appropriate.
Saunders' Motion to Extend Time to File PDR 2 of 3
Respectfully submitted
/S/ Richard Martin P. Canlas
RICHARD MARTIN P. CANLAS
Lawyer for Appellant
300 West Davis, Suite 560
Conroe, Texas 77301
Texas State Bar Number: 90001843
Tel: 936.788.6999
Fax Number: 936.788.5999
Certificate of Service
I certify that a true and correct copy of this motion was:
(a) faxed to Bill Delmore, Montgomery County District Attorney’s
Office, 936.760.6940, on December 17, 2015
/S/ Richard Martin P. Canlas
Richard Martin P. Canlas
Saunders' Motion to Extend Time to File PDR 3 of 3