PD-1597-15
PD-1597-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/10/2015 7:59:20 PM
Accepted 12/11/2015 12:37:59 PM
ABEL ACOSTA
NO. _____________ PD CLERK
IN THE
COURT OF CRIMINAL
APPEALS
OF TEXAS
___________________________________________
EX PARTE
JAMES AGBEZE
Petitioner,
_________________________________________________________
Petition in Cause No. 1288928 from the
TH
180 District Court of Harris County, Texas and
the Court of Appeals for the
14TH District of Texas
____________________
FIRST MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S PETITION FOR DISCRETIONARY REVIEW
____________________
TOM ABBATE
440 LOUISIANA, STE 200
HOUSTON, TX 77002
OFFICE: (713) 223-0404
FAX: (800) 501-3088
December 11, 2015 tom@tomabbatelaw.com
SBOT # 24072501
TO THE HONORABLE JUDGES OF THE TEXAS COURT OF CRIMINAL APPEALS:
Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Petitioner, JAMES AGBEZE, files
this First Motion to Extend Time to File his Petition for Discretionary Review.
Petitioner’s brief was due on DECEMBER 7, 2015.
Counsel for Petitioner requests a 4-day extension of time to file its brief, making the
brief due on DECEMBER 10, 2015. This is the first request for extension of time to file
the opening brief. This request is not sought for delay but so that justice may be done.
All facts recited in this motion are within the personal knowledge of the counsel
signing this motion, therefore no verification is necessary under Rule of Appellate
Procedure 10.2.
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant this
Unopposed First Motion to Extend Time to File his Petition for Discretionary Review and
extend the Deadline for Filing the Petitioner’s Brief up to and including DECEMBER 10,
2015. Appellant prays for all other relief to which it may be entitled.
Respectfully submitted,
_________________________
TOM ABBATE
440 LOUISIANA, STE 200
HOUSTON, TX 77002
OFFICE: (713) 223-0404
FAX: (800) 501-3088
tom@tomabbatelaw.com
SBOT # 24072501
Counsel for Petitioner
CERTIFICATE OF SERVICE
I certify that on DECEMBER 10, 2015, a true and correct copy of the forgoing
motion was delivered to the HARRIS County District Attorney’s Office by ELECTRONIC
MAIL.
_________________________
TOM ABBATE
SBOT: 24072501
Counsel for Petitioner