PD-1017&1018&1019-15 COURT
PD-1017&1018&1019-15
OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/7/2015 8:17:34 AM
Accepted 8/11/2015 1:30:11 PM
ABEL ACOSTA
PDR No. ____________________ CLERK
Court of Appeals Nos. 03-13-00390-CR, 03-13-00391-CR & 03-13-00392-CR
ANDREA STANLEY § IN THE TEXAS COURT OF
§
v. § CRIMINAL APPEALS
§
STATE OF TEXAS § AT AUSTIN, TEXAS
PETITIONER’S MOTION FOR EXTENSION OF TIME TO FILE
PRO SE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes ANDREA STANLEY, Petitioner in the above styled and
numbered cause, and moves this Court for a 90-day extension to file her Petition for
Discretionary Review, and would show as follows:
1. Petitioner has been convicted for the offenses of Aggravated Assault,
Aggravated Kidnaping, and Burglary of a Habitation. She has been assessed
sentences of 50 years and 20 years on the Aggravated Assault charges, 50 years on
the Aggravated Kidnaping charge, and 50 years on the Burglary of a Habitation
charge.
2. The Third District Court of Appeals issued an unpublished decision in
this case on July 30, 2015. Andria Stanley v. State of Texas, 03-13-00390-CR, 03-
13-00391-CR & 03-13-00392-CR (Tex.App. – Austin, July 30, 2015). The PDR in
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August 11, 2015
this case is due on or before August 31, 2015.
3. The undersigned counsel is appointed and his appointment has
terminated following the decision in this case. Counsel does not intend to continue
representation on a pro se basis. Counsel has advised Petitioner by letter on this date
regarding the termination of his representation and her right to seek a Petition for
Discretionary Review on a pro se basis, or through retained counsel.
4. In order to pursue her options, Petitioner needs time to retain counsel,
or to obtain the record and other necessary documents in which to prepare a PDR on
a pro se basis.
5. Accordingly, the undersigned counsel requests this Court extend the
deadline to file the PDR in this case by 90 days from the current due date.
5. Ms. Stanley’s personal information for the purposes of notices by this
Court is as follows:
Ms. Andria Stanley
# 01861816
TDCJ Mountainview Unit
2305 Ransom Road
Gatesville, TX 76528
WHEREFORE, PREMISES CONSIDERED, Petitioner prays that this
Court grant this Motion, and grant an additional 90 days to file a PDR in this case
Respectfully submitted,
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Law Office of Alexander L. Calhoun
4301 W. William Cannon Dr., Ste. B-150, # 260
Austin, TX 78749
Tele: 512/ 420-8850
Fax: 512/ 233 - 5946
Cell: 512/ 731-3159
Email: alcalhoun@earthlink.net
BY:_/s/ Alexander L Calhoun
Alexander L. Calhoun
State Bar No.: 00787187
Attorney for Andria Stanley
CERTIFICATE OF SERVICE
I hereby certify that on August 3, 2015, a copy of the above and foregoing motion
has been served by mail upon the Travis County District Attorney's Office, at the
following address:
Travis County District Attorney
P.O. Box 1748
Austin, TX 78711
upon the State Prosecution Attorney by U.S. Mail at the following address:
State Prosecuting Attorney
P.O. Box 13046
Capitol Station
Austin, Texas 78711
and upon Appellant by U.S. Mail to the following address:
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Ms. Andria Stanley
# 01861816
TDCJ Mountainview Unit
2305 Ransom Road
Gatesville, TX 76528
/s/ Alexander L Calhoun
Alexander L. Calhoun
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