PD-1389-15
FILED IN COURT OF CRIMINAL APPEALS
COURT OF CRIMINAL APPEALS AUSTIN, TEXAS
Transmitted 11/20/2015 12:21:26 PM
November 20, 2015 Accepted 11/20/2015 1:32:40 PM
ABEL ACOSTA
CLERK
ABELACOSTA, CLERK NO. PD-1389-15
IN THE COURT OF CRIMINAL APPEALS OF TEXAS $1*^ ^°°_j_ ,
TIMOTHY JAMES LINDBERG, Appellant,
v.
STATE OF TEXAS, Appellee
APPELLANT'S MOTION FOR LEAVE TO EXCEED WORD LIMIT
TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS:
NOW COMES Appellant, Timothy James Lindberg, by and through
his attorney of record Brian W. Salvant, and files this Motion for Leave to
Exceed the Word Limit for a petition for discretionary review under Tex. R.
App. Proc. 9.4(i)(2)(D), and in support thereof would respectfully show the
following:
I.
Under Tex. R. App. Proc. 9.4(i)(2)(D), a petition for discretionary
review to this Court must not exceed 4,500 words if computer-generated.
II.
Appellant's Petition for Discretionary Review, filed this day with this
Motion, is 9,317 words in length, excluding the contents that are not to be
included in calculating the length of a document pursuant to Tex. R. App.
Appellant's Motion for Leave to Exceed Word Limit
Proc. 9.4(i)(l). Said Petition presents six questions/grounds for review.
III.
Appellant's counsel believes his Petition for Discretionary Review is
not unnecessarily lengthy and articulates the questions/grounds presented for
review and the arguments in support thereof in a concise but thorough
fashion. Reducing the length of the Petition to conform with the word limit
set by Tex. R. App. Proc. 9.4(i)(2)(D) would severely undermine
Appellant's arguments and prevent him from completely developing his case
to this Court for review.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully
requests that this Court grant him leave to exceed the word limit for his
petition for discretionary review and therefore prays that this Court grant this
Motion and allow him to file his Petition for Discretionary Review as is.
Respectfully submitted,
/s/ Brian Salvant
Brian Salvant
SBN 24008387
610E.WeatherfordSt.
Fort Worth, Texas 76102
(817)334-7997
(817) 334-7998 (fax)
briani@.saivantiawiirai.eor
Appellant's Motion for Leaveto Exceed Word Limit
CERTIFICATE OF CONFERENCE AND SERVICE
The undersigned, Brian Salvant, certifies that he has been advised on
this day that the Tarrant County District Attorney's Office does not oppose
the granting of this motion and that a true copy of this document has been
mailed this day to the appellate division of the Tarrant County District
Attorney's Office located at 401 West Belknap Fort Worth Texas 76196 this
20th day of November, 2015.
/s/ Brian Salvant
Brian Salvant
Appellant's Motion for Leave to Exceed Word Limit