PD-0309-15, PD-0310-15 & PD-0311-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 3/20/2015 4:58:07 PM
Accepted 3/25/2015 9:44:50 AM
ABEL ACOSTA
No. ______________________ CLERK
IN THE COURT OF CRIMINAL APPEALS
OF TEXAS
KEITH WYLIE BOWMAN,
Petitioner–Appellant
v.
THE STATE OF TEXAS,
Respondent–Appellee
Petition for Discretionary Review
from the Fifth District Court of Appeals at Dallas
Cause Nos. 05-13-01741-CR, 05-13-01742-CR, and 05-13-01743-CR
Appeal from
of Dallas County, Texas
Cause Nos. F10-35883-W, F10-35927-W, and F10-35928-W
MOTION FOR EXTENSION OF TIME
TO FILE A PETITION FOR DISCRETIONARY REVIEW
Keith Wylie Bowman, Appellant below, respectfully submits this Motion
for an Extension of Time to File a Petition for Discretionary Review in the above–
styled and numbered cause. In support of this Motion, he shows this Honorable
Court the following:
March 25, 2015
I.
Appellant was convicted of three separate aggravated robbery charges. The
court sentenced him to 10 years’ imprisonment in one case and 20 years’
imprisonment in the other two cases.
II.
The Court of Appeals affirmed the trial court’s judgment in a memorandum
opinion and judgment filed on February 5, 2015. Bowman v. State, Nos. 05-13,
01741-CR, 05-13-01742-CR, and 05-13-01743-CR, 2015 Tex. App. LEXIS 1196
(Tex. App.—Dallas Feb. 5, 2015) (mem. op., not designated for publication).
Appellant filed a motion for rehearing in Appellate Cause No. 05-13-01742-CR,
which the Court of Appeals denied on March 9, 2015. Appellant’s petition for
discretionary review in that case is due April 8, 2015.
Appellant’s petition for discretionary review in Appellate Cause Nos. 05-13-
01741-CR and 05-13-01743-CR is due March 6, 2015. See TEX. R. APP. P.
68.2(a); see also TEX. R. APP. P. 4.1(a). Any motion for extension of time to file a
petition for discretionary review is due March 22, 2015. See TEX. R. APP. P.
68.2(c); TEX. R. APP. P. 4.1(a).
III.
The facts relied upon to show good cause for this requested extension are as
follows:
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1. Appellant was represented by court appointed counsel during appeal of
this case to the Court of Appeals.
2. It is undetermined at this time whether Appellant will proceed pro se for
purposes of filing a Petition for Discretionary Review in one or more of
these causes. Additional time is needed for consultation between
appellate counsel and Appellant on this issue.
3. If Appellant proceeds pro se, then additional time will be needed to
prepare and file the Petition pro se or to seek other legal assistance in
filing the Petition.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully
requests that this Honorable Court extend the time for filing a Petition for
Discretionary Review for sixty days.
Respectfully submitted,
Lynn Richardson
Chief Public Defender
Dallas County
Katherine A. Drew
Chief, Appellate Division
Dallas County Public Defender’s Office
/s/ Julie Woods
Julie Woods
Assistant Public Defender
Dallas County Public Defender’s Office
State Bar Number: 24046173
133 N. Riverfront Blvd., LB 2
Dallas, Texas 75207
(214) 653-3550 (telephone)
(214) 653-3539 (fax)
Julie.Woods@dallascounty.org
Attorneys for Petitioner
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CERTIFICATE OF SERVICE
I certify that a true copy of the foregoing Motion for Extension of Time to
File a Petition For Discretionary Review was served on Grace E. Shin, counsel for
the State, Dallas County District Attorney’s Office, 133 N. Riverfront Blvd., LB-
19, 10th Floor, Dallas, Texas 75207, by eServe on March 20, 2015.
I further certify that a true copy of the foregoing Motion for Extension of
Time to File a Petition For Discretionary Review was served on Lisa C. McMinn,
the State’s Prosecuting Attorney, P.O. Box 13046, Capitol Station, Austin, Texas
78711, by eServe on March 20, 2015.
/s/ Julie Woods
Julie Woods
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