Monala-Khalil, Salma

PD-1353-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/16/2015 12:00:00 AM Accepted 11/17/2015 10:57:59 AM ABEL ACOSTA CLERK NO; PD-1353-15 COA NO: 13-14-00191 CR TRIAL COURT CASE NO(sY E105654 TEXAS COURT OF CRIMINAL APPEALS SALMA MONALA-KHALIL AUSTIN, TEXAS APPEAL FROM THE COUNTY \v ^ COURT AT LAW NO. 2 vs. § OF THE STATE OF TEXAS, APPELLEE § ORANGE COUNTY, TEXAS MOTION TO EXTEND THE TIME FOR FILING APPELLANT'S PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF APPEALS: COMES NOW the Appellant and moves the Court for an extension of time to file a Appellant's Petition for Discretionary Review in this cause , and in support thereof would show the Court as follows: I. The Appellant was convictedof Driving While Intoxicated, 1SI Offenseon February 14th, 2014. At the same time the Defendant was sentenced to 180 days confinement in the Orange County Jail, and a $300.00 fine. At that time, on the finding of the court defendant was eligible for probation and that the jail sentence be suspended and the defendant.be placed on probation for a term of one (1) year; In the County Court at Law No. Two (2), of Orange County, Texas, in case styled as; THE STATE OF TEXAS VS. SALMA MONALA-KHALIL, under Cause No. E105654. FILED IN COURT OF CRIM1NALAPPEALS November 17, 2015 ABEL ACOSTA, CLERK II. That Appellant's Petition for Discretionary Review was due to be filed on the November 18,h day of November 2015. III. Appellant respectfully requests that this Honorable Court grant ah additional extension of approximately thirtydays or until the 18* day of December 2015. IV. That such extension is necessary for the following reasons: 1. Counsel's Daughter-in-Law just recently delivered her baby by emergency cesarean section. Counsel's other three grandchildren, older siblings of the newborn, have upper respiratory infections and counsel is keeping them to prevent passing it to the new baby. 2. Counsel has been heavily scheduled in multiple counties for pretrial and trial dockets. 3. This extension is not sought for delay only, but that justice may be done in this case. WHEREFORE, PREMISES CONSIDERED, Appellantrespectfully requestsandpraysthat this Honorable Court extend the time for the filing ofAppellant's Petition for Discretionary Review be filed herein approximately December 18th, 2015. Respectfully submitted, /s/Brvan S. Laine /s/Bryan S. Laine 1045 S.Redwood Kountze, Texas 77625 Tel: (409) 246-4008 Fax: (409) 246-3645 CERTIFICATE OF SERVICE ^ I hereby certifythat true and correct copyof the foregoing document has been forwarded to all associated parties in the foregoing, as indicated below, on this the 16,h of November 2015, /s/Bryan S. Laine /s/Bryan S..Laine State Bar No. 24011488 Texas Court of Criminal Appeals 201 West 14th Street Room #106 P. O. Box 12308 Capitol Station Austin. TX 78701. Tom Kelly Orange County District Attorney 801 Division Street Via facsimile (409) 883-9322 PD-1353-15 COA NO. 13-14-0191 CR TRIAL COURT CASE NOfs) E105654 TEXAS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS SALMA MONALA-KHALIL § APPEAL FROM THE COUNTY § COURT AT LAW NO. 2 § vs. § OF § THE STATE OF TEXAS, APPELLEE § ORANGE COUNTY, TEXAS ORDER On _, 20 , came on to be considered Salrha Monala Khalil's Motion for Extension in Time in Filing Appellant's Petition for Discretionary Review is hereby: (Granted) (Denied) JUDGE PRESIDING