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 Fourth District ofTexas affirmed the

judgment in Jimmy Turner v. The State of Texas, Cause No. 04-13-00886-CR. This cause had

been appealed from the 186^ Judicial District ofBexar County, Texas. Trial Court Number

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

CLERK
II.

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 sufficient time 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, Appellant prays the court grant this motion

and allow Petition for 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 TURNER
CERTIFICATE 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 of every statement herein and am fully competent and authorized to 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 affirm that 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 ofJuly 2015.

ROBERTS

Notary Public

STATE OF TEXAS

MyComm. Esp.August 10.2017

NOTARY PUBLIC IN AND FOR

THE STATE OF TEXAS