Bledsoe, Eric

PD-1543-15 PD-1543-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/24/2015 3:53:11 PM Accepted 11/25/2015 11:22:19 AM ABEL ACOSTA IN THE CLERK COURT OF CRIMINAL APPEALS ERIC BLEDSOE, § APPELLANT § V. § NO. _ § THE STATE OF TEXAS, § APPELLEE § APPELLANT’S MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW COMES NOW Eric Bledsoe, by and through Barry G. Johnson, his attorney of record, and files this motion to extend the time for thirty days to file a petition for discretionary review. I. The court of appeals below is the Court of Appeals for the Second Court of Appeals District. The style and number of the cases in the Fort Worth Court is Bledsoel v. State, No. 02-14-00450-CR. II. On October 29, the Fort Worth Court issued an opinion affirming the trial court’s judgment. See Bledsoe v. State, No. 02-14-00450-CR, (Tex. App.—Fort Worth October 29, 2015). Appellant did not file a motion for rehearing. November 25, 2015 III. The current deadline for filing the petition for discretionary review is November 28, 2015. Appellant now requests an extension of 33 days – until December 31, 2015 – to file the State’s petition. Appellant has not previously requested an extension of time to file a petition for review in this case. IV. This extension is not for the purposes of delay, but rather so that undersigned counsel may adequately set forth the Appellant’s position in its grounds for review. The undersigned has been working on this PDR, on a reply brief to this court in Isbell v. State, No. PD-0469-15 through -0472-15, as well as carrying a trial docket of civil and criminal cases. Wherefore, Appellant prays that the Court grant an extension of 33 days to December 31, 2015, for filing Appellant’s petition for discretionary review. 2 Respectfully submitted, Respectfully submitted, BARRY G. JOHNSON /s/ Barry G. Johnson BARRY G. JOHNSON 2821 E. Lancaster Fort Worth, Texas 76103 (817) 531-9665 FAX (817) 534-9888 State Bar No. 10683000 barrygj@aol.com /s/ Barry G. Johnson BARRY G. JOHNSON CERTIFICATE OF SERVICE A copy of the State's Motion to Extend Time to File Petition for Discretionary Review has been e-served to opposing counsel, the Hon. D e b r a Windsor, om November 24, 2015. /s/ Barry Gt. Johnson BARRY G. JOHNSON 3