Bolen, Chance Douglas

PD-1464-15 PD-1464-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/11/2015 10:05:41 AM Accepted 11/12/2015 2:04:36 PM No. 07-15-00071-CR ABEL ACOSTA CLERK CHANCE BOLEN § IN THE COURT OF APPEALS § V. § OF THE SEVENTH SUPREME § STATE OF TEXAS § JUDICIAL DISTRICT MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW the Appellant, by and through his counsel, David Crook, and files this motion for an extension of 30 days or the maximum amount of time possible in which to file his Petition for Discretionary Review in the above-referenced appeal. In support of this motion, Appellant would show the Court the following: I. On October 14, 2015, the Seventh Court of Appeals, in Appellate No. 07-15- 00071-CR, styled Chance Bolen v. the State of Texas, affirmed the judgment of the Court below. II. The present deadline for filing Appellant’s Petition for Discretionary Review is November 13, 2015. The Appellant has not requested any extensions with regard to his P.D.R. prior to this request. III. Appellant's request for an extension is based upon the following facts: Counsel has been spending some time in Shreveport, Louisiana, as Counsel’s 88-year old mother requires some attention to her affairs regarding her increasing hearing and vision problems. November 12, 2015 Prayer WHEREFORE, appellant prays that the Court grant this motion and extend the deadline for filing the Appellant’s Petition for Discretionary Review in Appellate No. 07- 15-00071-CR to Monday, December 14, 2015. Respectfully submitted, Crook & Jordan By: /s/David Crook David M. Crook PO Box 94590 Lubbock, TX 79493 (806) 744-2082 SBN: 05109530 Telephone: (806) 744-2082 Fax: (806) 744-2083 dcrook@nts-online.net Attorney for Appellant CERTIFICATE OF SERVICE This is to certify that a copy of the above-entitled and numbered motion has been served on Jeff Ford, attorney for the state, by e-mail, on this the 11th day of November, 2015. /s/David Crook DAVID CROOK Appellant’s M.Xtn.PDR 2