PD-1131-15
PD-1131-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/31/2015 3:41:33 PM
Accepted 9/1/2015 12:06:29 PM
ABEL ACOSTA
NO. PD.________________ CLERK
_________________________________________________________________
IN THE COURT OF CRIMINAL APPEALS
OF TEXAS
REMUS LITOIU,
APPELLANT
V.
THE STATE OF TEXAS,
APPELLEE
__________________________________________________________________
On Petition For Discretionary Review From The Thirteenth Court Of
Appeals In No. 13-13-00489-CR affirming the conviction in cause number S-
13-3012-Cr, from the District Court Of San Patricio County, Texas
APPELLANT’S MOTION FOR EXTENSION OF TIME
Respectfully submitted,
/s/ Les Cassidy
Les Cassidy
814 Leopard Street
Corpus Christi, Texas 78401
September 1, 2015 361-887-2965 (office)
361-885 -0320 (fax)
State Bar No. 03979270
Attorney for Appellant,
REMUS LITOIU
__________________________________________________________________
Now comes Remus Litoiu, Appellant, and moves this Court to grant an
extension of time to file appellant's Petition for Discretionary Review, pursuant to
Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows
the following:
1. This case was on appeal from the 36th Judicial District Court of San Patricio
County, Texas.
2. The style of the case in the 13th Court of Appeals was REMUS LITOIU vs.
STATE OF TEXAS, and numbered 13-13-00489-CR.
3. Notice of the Opinion and Judgment from the Court of Appeals was given
on July 30, 2015.
4. The appellate Petition for Discretionary Review is presently due on August
31, 2015.
5. Appellant requests an extension of time of 15 days from the present due
date, i.e. August 31, 2015, to file his Petition for Discretionary Review.
6. This Motion is timely filed less than 15 days after the last day for filing a
Petition for Discretionary Review.
7. No prior extensions to file the appellant’s Petition for Discretionary Review
have been requested in this cause.
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8. Appellant relies on the following facts as good cause for the requested
extension:
Counsel needs additional time to adequately prepare the Appellant's Petition for
Discretionary Review for filing and Counsel is asking for a 15-day extension to properly
complete the Petition. Appellate Counsel’s paralegal, Alice Sheets, was out of the office
during the week of August 24 – 28, 2015, while under subpoena in a case pending in the
214th Judicial District Court in Nueces County, in which she was a testifying witness.
Appellate counsel has multiple trial settings in District and County Courts and will be
busy resolving two matters on August 31, 2015 through September 2, 2015. A 15-day
extension will allow more time for the filing of an appropriate Petition for Discretionary
Review.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court
grant this Motion for Extension of Time to File Appellant's Petition for Discretionary
Review, and for such other and further relief as the Court may deem appropriate.
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CERTIFICATE OF SERVICE
I certify that a true copy of the above was served in accordance with the Texas
Rules of Civil Procedure on this the 31st day of August 2015, on the following:
Via Fax 361-364-9490
San Patricio District Attorney
400 West Sinton Street, Room 108
Sinton, Texas 78387
_/s/ Les Cassidy _________________
Les Cassidy
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