PD-1566-15
PD-1566-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/3/2015 2:43:34 PM
Accepted 12/4/2015 12:28:29 PM
ABEL ACOSTA
CLERK
CAUSE NO. _________________
COURT OF CRIM INAL APPEALS
AUSTIN, TEXAS
____________________________________________
COURT OF APPEALS NO. 08-13-00013-CR
TRIAL COURT NO. 20060D02425-DCR-1
EX PARTE: ANNA KNELSEN
____________________________________________________________________
M OTION FOR AN EXTENSION
OF TIM E TO FILE PETITION FOR DISCRETIONARY REVIEW
________________________________________________________________________
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
Petitioner, Anna Knelsen, files this Motion for Extension of Time to File
Petition for Discretionary Review under Tex. R. App. P. 10.1, 10.5(b), and 53.7(f).
In support of this motion, Petitioner shows the following:
1. The Eighth Court of Appeals in El Paso, Texas rendered its opinion and
judgment in Ex Parte: Anna Knelsen, No. 08-13-00013-CR, on August 26, 2015, an
extension of time to file motion for rehearing was filed on September 25, 2015, a
motion for rehearing was filed on September 25, 2015 and denied on November 5,
2015. The petition for review due date for filing is due on December 5, 2015.
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December 4, 2015
2. Petitioner requests an extension of time of thirty days, to January 5, 2016. This
is Petitioner's first request for an extension of time in this case.
3. Petitioner relies on the following facts as a reasonable explanation for the
requested extension of time:
The undersigned, was appointed and is the second attorney in an appeal of a
murder case styled The State of Texas v. Fidencio Valdez, AP-77,042 and has been
working on this brief. He prepared for trial on a murder trial case styled The State of
Texas v. Ricardo Macias, No. 20130D03635 which took a substantial amount of time.
The undersigned also had to complete a Petition for Discretionary Review on filed
on November 30, 2015 in a case styled Ex Parte Kerry G. Jones, PD-1373 & 1374 &
1375-15 ; and is currently working on two appeal briefs in the Eighth Court of Appeals
in The State of Texas v. Frances Mutei and In the Interest of N.P.M., a Child, both
due December 10 & 11, 2015. The undersigned has also been very busy with court
hearings, client conferences and a conferences with investigators all of which have
prevented him from writing the Petition for Review by the deadline of December 5,
2015, necessitating the filing of this extension request.
Therefore, Petitioner prays that this Court grant this motion for extension of
time.
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Respectfully submitted,
/s/ Jam es D . Lucas
JAM ES D. LUCAS
SBN 12658300
2316 M ontana Avenue
El Paso, Texas 79903
Tel: (915) 532-8811
Fax: (915) 532-8807
Counsel for Petitioner
jlucas2@ elp.rr.com
CERTIFICATE OF SERVICE
I, James D. Lucas, hereby certify that on the 3rd day of December, 2015, a true and
correct amended copy of the foregoing instrument was delivered to the below-named
individuals by electronic means:
Jaime Esparza
District Attorney
El Paso County Courthouse
500 E. San Antonio, Room 201
El Paso, Texas 79901
tdarnold@ epcounty.com
State Prosecuting Attorney
P.O. Box 12405
Austin, Texas 78711
inform ation@ spa.texas.gov
Dated this 3 rd day of December, 2015.
/s/ Jam es D . Lucas
JAM ES D. LUCAS
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