PD-1389-15
PD-1389-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 10/23/2015 3:27:35 PM
October 27, 2015 Accepted 10/27/2015 4:10:48 PM
ABEL ACOSTA
CLERK
NO. ---
IN THE COURT OF CRIMINAL APPEALS OF TEXAS
TIMOTHY JAMES LINDBERG, Appellant, v. STATE OF TEXAS, Appellee
APPELLANT'S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS:
1. On September 24,2015, the Second Court of Appeals issued its opinion in
this cause (Lindberg v. State, Cause No. 02-14-00071-CR). No motion for rehearing
or motion for reconsideration en bane was filed. Therefore, a petition for
discretionary review must be filed by October 24, 2015, which is 30 days after the
Court of Appeals' judgment was rendered. See Tex. R. App. P. 68.2(a). Appellant
seeks a 30-day extension of this deadline.
2. Appellant has not sought or been granted a previous extension of time to
file a petition.
3. The undersigned counsel was just appointed by the trial court from which
this cause was appealed to petition this court for review of the Court of Appeals'
decision in this case. Undersigned counsel has two felony cases set for trial next
month (one the week of November 2 and the other the week of November 9), a
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motion for rehearing and a motion for reconsideration en bane on another case due
on October 26, and an Appellee's Brief for another case due on October 28.
4. Appellee does not oppose this motion.
Based on the foregoing, Appellant asks that the deadline to file his petition for
discretionary review be extended to November 23,2015.
Respectfully Submitted,
Isl Brian Salvant
Brian Salvant
Texas Bar No. 24008387
610 East Weatherford Street
Fort Worth, Texas 76102
Telephone: (817) 334-7997
Facsimile: (817) 334-7998
E-Mail: brian@salvantlawfirm.com
Attorney for Appellant
CERTIFICATE OF CONFERENCE
The undersigned certifies that he conferred with Debra Windsor, counsel for
Appellee, who stated that she does not oppose the relief sought by this motion.
Isl Brian Salvant
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of this instrument was served
upon Debra Windsor, Assistant Criminal District Attorney, Tim Curry Criminal
Justice Center, 401 W. Belknap Fort Worth, Texas 76196, by electronically
emailing, and by placing same in the United States mail, proper postage affixed, on
October 23,2015.
Isl Brian Salvant
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