PD-1393-15
PD-1393-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 10/27/2015 2:48:15 PM
October 27, 2015 Accepted 10/27/2015 5:15:06 PM
ABEL ACOSTA
No. ___________ CLERK
In the
COURT OF CRIMINAL APPEALS
______________________________________
On Appeal from the 400th Judicial District Court of
Fort Bend County, Texas, Cause Number 11-DCR-59007A;
and the Opinion of the Fourteenth Court of Appeals
in Cause Number 14-14-00272-CR, Delivered October 15, 2015
______________________________________
JEREMY PATRICK SHAKESNIDER
v.
THE STATE OF TEXAS
_____________________________________
MOTION FOR EXTENSION OF TIME TO FILE
PRO SE PETITION FOR DISCRETIONARY REVIEW
______________________________
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL
APPEALS:
COMES NOW, Michael Elliott, the undersigned attorney of record for
Jeremy Patrick Shakesnider, the Appellant, herein, and files this Motion for
Extension of Time to File Pro Se Petition for Discretionary Review. As set out
below, the undersigned respectfully requests a thirty-day extension so that
Appellant can file his Pro Se Petition for Discretionary Review. In support of
said motion, the undersigned would show the Court the following:
1. Appellant’s Petition for Discretionary Review is currently due in this
case on November 14, 2015.
2. Appellant seeks an extension of thirty days in which to file his
Petition for Discretionary Review, making his Petition due on or before December
14, 2015.
3. The undersigned counsel will not be representing Appellant after the
filing of this motion. Appellant will now have to obtain and review the record in
order to prepare and file a Pro Se Petition for Discretionary Review. The
undersigned believes that there is insufficient time between now and November 15,
2015, to accomplish those goals. Consequently, the undersigned respectfully
requests that the Court grant Appellant the additional time.
4. The undersigned has not filed any previous motions for extension of
time in this case.
5. For the reasons set forth above, the undersigned respectfully requests
that Appellant be granted an extension of thirty days so that his brief in this case
will now be due on December 15, 2015.
PRAYER
WHEREFORE, PREMISES CONSIDERED, the undersigned
respectfully requests that this Court grant this Motion for Extension of Time to File
Pro Se Petition for Discretionary Review.
Respectfully submitted,
_______/s/__Michael Elliott______
Michael Elliott
State Bar Number 06546540
905 Front Street
Richmond, Texas 77469
(832) 496-5000
(281) 232-8141 (fax)
mike@elliottslaw.com
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the
foregoing Appellant’s Motion for Extension of Time has been mailed to the Fort
Bend County District Attorney’s 301 Jackson Street, Richmond, Texas 77469 on
October 27, 2015.
__/s/ Mike Elliott__________________
Mike Elliott
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