Quintero, Juan

PD-0746-15
PD-0746-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/18/2015 10:53:56 AM
Accepted 6/19/2015 2:15:42 PM
ABEL ACOSTA
CLERK
No. PD-_________
In the Court of Criminal Appeals of Texas
⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯
No. 14-13-00559-CR
In the Fourteenth District Court of Appeals (Houston, Texas)
⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯
No. 1368190
In the 228th District Court, Harris County, Texas
⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯
JUAN QUINTERO,
Petitioner
v.
THE STATE OF TEXAS,
Respondent
⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯
PETITIONER’S MOTION FOR EXTENSION OF TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯⎯

PEYTON Z. PEEBLES, III
SHELLIST, PEEBLES & MCALISTER, LLP
405 Main Street, Suite 200
Houston, Texas 77002
June 19, 2015 Tel.: (713) 715-4500
Fax: (713) 715-4505
Email: peebles@texaslegalteam.net
SBOT: 24013307
Counsel for Petitioner

1
TO THE HONORABLE COURT OF CRIMINAL
APPEALS OF TEXAS:

Petitioner Juan Quintero, through his undersigned counsel and
in accordance with Tex. R. App. P. 2, 10.5(b), and 68.2(c), respect-
fully moves this Court for more time in which to file his petition for
discretionary review (“PDR”) in this case. Petitioner offers the fol-
lowing in support:
1. Petitioner requests a 30-day extension of time in which to
file his PDR.
2. The PDR is due today, June 18, 2015.
3. A divided panel from the Fourteenth District Court of Ap-
peals issued its majority and dissenting published opin-
ions, and judgment affirming petitioner’s conviction, on
May 19, 2015.
4. Petitioner did not file a motion for rehearing or motion
for en banc reconsideration.
5. Petitioner was convicted of aggravated sexual assault of a
child and received a 6-year prison sentence pursuant to a
plea bargain.
6. The undersigned counsel requires more time to draft peti-
tioner’s PDR for the following reasons:
a. Counsel has been in trial, or preparing for trial

2
 and/or sentencing, in many matters, some of which
are:
i. State of Texas v. John Lancey, No. 1405593 in
the 184th District Court of Harris County, Tex-
as;
ii. State of Texas v. Jose Garza, No. 1453925 in the
209th District Court of Harris County, Texas;
iii. State of Texas v. Alfonso Martinez, No. 1453358
in the 338th District Court of Harris County,
Texas;
iv. United States v. Svetalina Zagon, No. 12-CR-
00626-SJ in the United States District Court
for the Eastern District of New York (Brooklyn
Division); and
b. During the relevant time period the undersigned
counsel has been working on numerous post-
conviction writ matters, some of which are:
i. Ex parte Jaime Vasquez, No. 720173-A (original
case) in the 177th District Court of Harris
County, Texas;
ii. Ex parte Javier Castro, No. 1966885 in the
County Criminal Court at Law No. 6 of Harris

3
 County, Texas; and
c. The undersigned counsel was out of town on vaca-
tion from June 9, 2015, through June 13, 2015.
7. The undersigned counsel asks that time to file this PDR be
extended to July 20, 2015 (the 18th falling on a Saturday).

Consequently, additional time will necessary in order to prepare
petitioner’s PDR in this matter.

PRAYER FOR RELIEF
For the foregoing reasons, Petitioner prays that this Court grant
him an extension of time to file this PDR until July 20, 2015.

Respectfully submitted,
SHELLIST, PEEBLES & MCALISTER, L.L.P.
By:
/s/ Peyton Z. Peebles III
____________________________________________________

PEYTON Z. PEEBLES III

405 Main Street, Suite 200
Houston, TX. 77002
Tel: 713-715-4500
Fax: 713-715-4505
Email: peebles@texaslegalteam.net
SBOT: 24013307
SPN: 01759419
Counsel for Petitioner

4
 ⎯⎯⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯⎯⎯

CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing
motion was served upon the parties designated below by e-filing on
June 18, 2015.

Clinton A. Morgan
Harris County Assistant District Attorney
1201 Franklin, Suite 600
Houston, Texas 77002
(service by e-file to morgan_clinton@dao.hctx.net)

Lisa C. McMinn
Texas State Prosecuting Attorney
P.O. Box 13046
Capitol Station
Austin, Texas 78711
(service by e-file to information@spa.texas.gov)

/s/ Peyton Z. Peebles III
____________________________________________________

PEYTON Z. PEEBLES III

5