PD-0995-15, PD-0996-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/31/2015 9:49:31 PM
AUGUST 6, 2015 Accepted 8/6/2015 9:40:31 AM
ABEL ACOSTA
CLERK
No. ________
__________________________________________
IN THE
TEXAS COURT OF CRIMINAL APPEALS
__________________________________________
KENNETH TURNER,
Petitioner,
V.
STATE OF TEXAS,
Respondent.
__________________________________________________________________
FIRST MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR REVIEW
__________________________________________________________________
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
Petitioner files this First Unopposed Motion for Extension of Time to
File Petition for Discretionary Review under Tex. R. App. P. 10.5(b) and
68.2(c). In support of this motion, Petitioner shows the following:
I.
The Court of Appeals for the Fifth District in Dallas rendered its
opinion and judgment in Kenneth Turner vs. The State of Texas, No: 05-13-
01486 CR and No: 05-13-01487 CR, on October 29, 2014. Petitioner timely
Motion for Extension 1
filed his Motion for Rehearing and the Court of Appeals for the Fifth District
in Dallas rendered its opinion affirming the judgment on December 19,
2014. Petitioner timely filed his Motion for En Banc Reconsideration and
the Court of Appeals affirmed the judgment on June 16, 2015. The Petition
for Discretionary Review was due no later than July 16, 2015.
II.
Petitioner requests an extension of time of thirty days, to August 30,
2015. This is Petitioner’s first request for an extension of time in this case.
III.
Petitioner relies on the following facts as a reasonable explanation for
the requested extension of time. Petitioner’s counsel, request an extension in
order to adequately brief the complex legal issues presented by this appeal
IV.
WHEREFORE, PREMISES CONSIDERED, Petitioner prays that
this Court grant this motion for extension of time.
Motion for Extension 2
Respectfully Submitted,
/s/ Darian Howard
DARIAN HOWARD
SBN: 24067669
P.O. Box 411252
Dallas, Texas 75241
(972)437.3801 (Telephone)
(972)437.3139 (Facsimile)
ATTORNEY FOR KENNETH TURNER
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and
foregoing instrument has been served electronically on the Dallas County
District Attorney on this the 31st day of July 2015.
/s/ Darian Howard .
Darian Howard
Motion for Extension 3