PD-1452-15
PD-1452-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 11/6/2015 8:29:26 AM
November 9, 2015 Accepted 11/9/2015 3:51:34 PM
NO. ABEL ACOSTA
CLERK
IN THE
COURT OF CRIMINAL APPEALS
OF TEXAS
NO. 13-13-00496-CR
IN THE COURT OF APPEALS
FOR THE
THIRTEENTH JUDICIAL DISTRICT OF TEXAS
CORPUS CHRISTI, TEXAS
THE STATE OF TEXAS § APPELLANT
§
V. §
§
BRITTANY WYATT § APPELLEE
APPEAL FROM COUNTY COURT AT LAW NO. 3
NUECES COUNTY, TEXAS
APPELLEE'S MOTION FOR EXTENSION OF TIME
TO FILE APPELLEES PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES, BRITTANY WYATT, Appellee in the above entitled and
numbered cause, by and through her attorney of record, W. TROY McKINNEY, and
submits this Motion for Extension of Time to file Appellee's Petition for
Discretionary Review until December 7, 2017. For good cause, Appellee shows as
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follows.
1. This Court issued its opinion on June 4, 2015. On July 20, 2015,
Appellee’s motion for rehearing was filed and it was overruled on October 6, 2015.
This petition for discretionary review is due to be filed on or about November 5,
2015. This is Appellee's first request for an extension of time to file Appellee's
Petition for Discretionary Review.
2. The last thirty days, Appellee's counsel has been in trial, had an
extremely heavy court docket in Harris County, Texas, and several out of town court
settings.
3. Furthermore, Appellee’s counsel was in Oklahoma City and Corpus
Christi speaking at seminars.
4. This Motion is not made for delay, but to see that justice is done.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellee prays that the
deadline for filing of Appellee's Petition for Discretionary be extended to December
7, 2015.
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Respectfully submitted,
SCHNEIDER & McKINNEY, P.C.
/w/ Troy McKinney
W. Troy. McKinney
T.B.C. No. 13725020
440 Louisiana
Suite 800
Houston, Texas 77002
713-951-9994
FAX 713-224-6008
Email: wtmhousto@aol.com
ATTORNEY FOR APPELLEE
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the attached and foregoing
document has been served on Williams Ainsworth, Assistant District Attorney, 901
Leopard, Room 206, Corpus Christi, Texas 78401.
/s/ W. Troy McKinney
W. Troy McKinney
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