NO. ______________________ 

IN THE COURT OF CRIMINAL APPEALS 

OF TEXAS 

EMILIO RODRIGUEZ V. THE STATE OF TEXAS

FROM THE SEVENTH COURT OF APPEALS 

CAUSE NO. 07-14-00202-CR

ON APPEAL FROM CAUSE NO. 2014-401,172 

IN THE 364TH DISTRICT COURT 

LUBBOCK COUNTY, TEXAS 

HON. BRAD UNDERWOOD, JUDGE PRESIDING 

HON. JOHN J. MCCLENDON, JUDGE PRESIDING BY ASSIGNMENT 

CECIL G. PURYEAR, JUDGE PRESIDING BY ASSIGNMENT 

APPELLANT’S MOTION FOR EXTENSION OF TIME 

TO FILE PETITION FOR DISCRETIONARY REVIEW

JULIE GOEN PANGER

Counsel for Appellant/Petitioner 

The Kiechler Law Firm 

619 Broadway Street 

Lubbock, Texas 79401 

Telephone (806) 712-2889 

Facsimile (808) 712-2529 

State Bar Number 24069793 

Email: julie@thelubbocklawyer.com

April 10, 2015 

PD-0406-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 4/10/2015 2:21:43 PM

Accepted 4/15/2015 3:50:16 PM

ABEL ACOSTA

CLERK
To the Honorable Court of Criminal Appeals of Texas:

COMES NOW, EMILIO RODRIGUEZ, Appellant/Petitioner herein, and files 

this Motion for Extension of Time to File Petition for Discretionary Review pursuant 

to TEX. R. APP. P. 10.1, 10.5, and 68.2, and in support thereof would show the Court 

as follows:

I.

The opinion of the Seventh Court of Appeals in Cause No. 07-14-00202-CR, 

affirming the conviction, was rendered on February 25, 2015.

II.

The number and style of the case in the District Court is Cause No. 2014-

401,172, State of Texas v. Emilio Rodriguez.

III.

Appellant/Petitioner was convicted by a jury of robbery, enhanced by prior 

felony convictions. He was then sentenced to ninety-nine (99) years’ imprisonment.

IV.

The original deadline for filing the petition for discretionary review was March 

27, 2014. This Motion is being filed within fifteen (15) days of such deadline, pursuant 

to Rule 10.5(b) of the Texas Rules of Appellate Procedure.

V.

No extensions of time to file the petition for discretionary review have been 

previously requested or granted.
VI.

Counsel for Appellant relies on the following reasons, in addition to the routine 

matters that counsel must attend to in daily practice, to explain the need for the 

requested extension:

A. Counsel has been made aware of a United States Supreme Court 

case, decided on March 30, 2015, which specifically relates to the 

facts of this case and will likely have a bearing on this Court’s review 

of this case. See Woods v. Donald, 575 U.S. ____ (2015), No. 14-618, 

decided March 30, 2015.

VII.

Counsel for Appellant seeks this extension of time to be able to prepare a cogent 

and succinct petition to aid this Court in its analysis of the issues presented. This request 

is not sought for delay but so that justice may be done.

VIII.

WHEREFORE, PREMISES CONSIDERED, Appellant requests that this 

Court grant an extension of time to file the petition for discretionary review until April 

24, 2015.
Respectfully submitted,

The Kiechler Law Firm PLLC

619 Broadway

Lubbock, Texas 79401

806.712.2889p

806.712.2529f

julie@thelubbocklawyer.com

_/s/ Julie Goen Panger_________

Julie Goen Panger

SBN: 24069793

CERTIFICATE OF SERVICE

I certify that on April 10, 2015, I provided a copy of this Motion to Jeff Ford, 

Lubbock County District Attorney, Attorney for the State, by electronic service at 

jford@lubbockcda.com.

_/s/ Julie Goen Panger_________

Julie Goen Panger