PD-0968-15
PD-0968-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/27/2015 1:05:46 PM
July 28, 2015 Accepted 7/28/2015 3:10:28 PM
ABEL ACOSTA
No. ___________ CLERK
In the
COURT OF CRIMINAL APPEALS
______________________________________
On Appeal from the 130th Judicial District Court of
Matagorda County, Texas
Cause Number 13-094; and the
Opinion of the Thirteenth Court of Appeals
in Cause Number 13-13-00328-CR, Delivered July 23, 2015
______________________________________
FRANK LARA, JR.
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, Kristen Jernigan, the undersigned attorney of record for
Frank Lara, Jr., 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 sixty-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 July 24, 2015.
2. Appellant seeks an extension of sixty days in which to file his Petition
for Discretionary Review, making his Petition due on or before October 26, 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 July 24, 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 sixty days so that his petition for
discretionary review in this case will now be due on October 26, 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/__Kristen Jernigan______
KRISTEN JERNIGAN
State Bar Number 90001898
207 S. Austin Ave.
Georgetown, Texas 78626
(512) 904-0123
(512) 931-3650 (fax)
Kristen@txcrimapp.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
Matagorda County District Attorney’s Office c/o Robinson C. Ramsey, attorney of
record for the State, Trinity Plaza II Suite 900, 745 E Mulberry Ave., Ste 900, San
Antonio, Texas 78212-3141, on July 27, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
2
Lara, Frank Jr.
Combined Opinion