IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS AUSTIN, TEXAS

JIMMY TURNER Appellant

V.
THE STATE OF TEXAS Appellee NO. 04-13-00886-CR

Petition in Cause No. 2031-CR-6595-B and the Court ofAppeals for the Fourth District of Texas. APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW Appellant, JIMMY TURNER, and pursuant to Rule 10.1 and Rule 10.5 of the Texas Rules ofAppellant Procedure, and files this Motion to Extend Time to File Petition for Discretionary Review. In support ofsaid motion, the Defendant would show as follows: I. On June 17, 2015, the Court ofAppeals for the FourthDistrict ofTexas affirmed the judgmentin Jimmy Turnerv. The State ofTexas, Cause No. 04-13-00886-CR. This cause had 

## been appealed from the 186^Judicial DistrictofBexarCounty, Texas. Trial CourtNumber 2013-CR-6595-B. 

### PD-0893-15 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 7/17/2015 1:48:59 PM Accepted 7/17/2015 4:43:03 PM

ABEL ACOSTA CLERKII. 

### The Petition for Discretionary Review is due on July 17, 2015. The Appellant has not requested previous extensions in which to file Petition. III. 

### Appellant would show that the following are reasonable explanationsfor the requested extension: 

### Appellant is filing a Petition for Discretionary Review Pro Se. In order to have sufficienttime to prepare Petition for Discretionary Review, Appellant would request an extension to file Petition for Discretionary Review to October 7,2015. Counsel consulted with the Bexar County Appellate Division and they have no objection to this request. WHEREFORE, PREMISES CONSIDERED, Appellantprays the court grant this motion and allow Petitionfor Discretionary Review to be filed on October 7,2015. Respectfully submitted, LAW OFFICE OF PAMELA J. LAKATOS

PAMELA J.LAKlj^TOS TEXAS BAR CARD #04825600 3191 MEDICAL CENTER DRIVE APT 23105 MCKINNEY, TEXAS 75069 COUNSEL FOR APPELLANT JIMMY TURNERCERTIFICATE OF SERVICE 

### This is to certify that a true and correct copy ofthe foregoing motion was delivered to Bexar County District Attorney's Office, via email on July, 17,2015.

PAMELA J. LAKATOS 

# r
AFFIDAVIT OF PAMELA J. LAKATOS IN SUPPORT OF APPELLANT'S MOTION FOR ENLARGEMENT OF TIME wrnnN which to file appellant's brief STATE OF TEXAS § COUNTY OF COLLIN § BEFORE ME, the undersigned authority, personally appeared PAMELA J. LAKATOS, 

### known to me to be the attorney ofrecord for JIMMY TURNER, in the capacity stated, and who after being duly sworn, deposed and said: "My name is PAMELA J. LAKATOS. I am over the age of21 years. I have personal knowledge ofevery statement herein and am fully competent and authorizedto testify to these 

### matters. I am licensed to practice law in the State ofTexas. I am the attorney ofrecord for JIMMY TURNER. 

### "I have read Appellant's Motion for Extension ofTime Within Which to File Petition for Discretionary Review, and I swear and affirmthat all ofthe information contained therein is true and correct to my knowledge." FURTHER AFFIANT SAYETH NOT, Xi) _ . r\ PAMELA J. LAKATOS SUBSCRIBED AND SWORN TO BEFORE ME the undersigned authority on this the 

## Bk. day of July2015.

ROBERTS Notary Public STATE OF TEXAS MyComm. Esp.August 10.2017 NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS