Winston, Bravern

PD-1512-15 PD-1512-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/23/2015 8:21:52 AM Accepted 11/23/2015 11:23:35 AM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK FOR THE STATE OF TEXAS BRAVERN WINSTON * Appellant * * vs. * No. PD * COA No. 10-14-00139-CR THE STATE OF TEXAS, * Appellee * MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF APPEALS: COMES NOW, the Appellant, by and through her undersigned Attorney of Record, and respectfully moves the Court to extend the time for filing a petition for discretionary review in this cause, and in support therefore would show the Court as follows: I. That appellant was found guilty of the offense of Burglary of a Habitation in Cause No. 37,811 in the 66th District Court of Hill County, Texas. Appellant appealed his conviction to the Court of Appeals for the Tenth Judicial District. That court affirmed the trial court decision in an opinion delivered on October 29, 2015. II. Appellant’s petition for discretionary review is currently due on November 29, 2015 November 23, 2015 V. Appellant hereby requests an extension of time to file his Petition for Discretionary Review until December 29, 2015, and as reasons therefore would show this cause as follows: Counsel does not have sufficient to time to properly prepare a petition for discretionary review by the current due date, and for that reason seeks additional time to do so. Counsel would show that he has had several matters to deal with in the last thirty days. As a result, counsel has not had sufficient time to devote to the petition in this case.. WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests this honorable court to extend the time for filing Appellant's Petition for Discretionary Review in this cause to December 29, 2015. Respectfully submitted, /s/ Walter M. Reaves, Jr. Walter M. Reaves, Jr. 100 N. 6 th Street, Suite 802 Waco, Texas 76701 (254) 296-0020 FAX (877) 726-4411 TBA#16644200 walterreaves@att.net CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing motion was delivered to Abel Reyna, District Attorney for McLennan County, Texas, on November 20, 2015. /s/ Walter M. Reaves, Jr. Walter M. Reaves, Jr.