PDR#: TO BE ASSIGNED 

COURT OF APPEALS NUMBER 13-13-00579-CR 

IN THE COURT OF CRIMINAL APPEALS 

FOR THE STATE OF TEXAS 

CHRISTOPHER LONG, 

APPELLANT, 

v. 

STATE OF TEXAS, 

APPELLEE. 

FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE PETITION FOR DISCRETIONARY REVIEW 

TO THE HONORABLE COURT OF CRIMINAL APPEALS: 

COMES NOW, APPELLANT, CHRISTOPHER LONG'S COURT 

APPOINTED COUNSEL FOR DIRECT APPEAL, and files this motion to 

request that the time for filing a Petition for Discretionary Review in this 

cause be extended by 90 days and as reasonable explanation for the 

extension, would show the following: 

I. 

Appellant's Motion for Rehearing in this cause was denied by the 13th 

Court of Appeals, on or about, February 6, 2015. Appellant's Petition for 

PD-0259-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 3/9/2015 4:50:45 PM

Accepted 3/10/2015 10:32:39 AM

ABEL ACOSTA

CLERK
Discretionary Review is due on, or about, March 9, 2015. 

II. 

This extension is not sought for purposes of delay. The undersigned, 

is Appellant's court appointed attorney for direct appeal and requests that 

Appellant be granted an additional 90 days to file a PDR due to the 

following. The undersigned has been unable to find a current mailing 

address for Appellant. The undersigned has therefore been unable to inform 

Appellant that he may file a Petition for Discretionary Review (PDR) with 

the Court of Criminal Appeals, but also, that he is not entitled to a court 

appointed lawyer to file a PDR for him. 

III. 

The undersigned respectfully requests that the Court extend the time 

for filing a Petition for Discretionary Review in order that the undersigned 

can provide notice to, and opportunity for, Appellant to review the record 

more extensively, hire an attorney (if possible) to assist with the preparation 

of a Petition for Discretionary Review, or prepare and file a Petition for 

Discretionary Review pro se. 

Due to the foregoing, the undersigned respectfully requests a 90 day 

extension for filing of the Petition for Discretionary Review and to allow the 

Appellant to continue pursuing this appeal. 
IV. 

There has been no previous request for extension. 

v. 

The undersigned has conferred with the State regarding this motion 

and the State is not opposed to this request. 

WHEREFORE, Appellant requests the Court of Criminal Appeals 

extend the time for filing Appellant's Petition for Discretionary Review, and 

for such other and further relief to which the undersigned is justly entitled. 

Respectfully submitted, 

LUIS A. MARTINEZ, P.C. 

209 W. Juan Linn 

P.O. Box410 

Victoria, Texas 77902-0410 

(361) 676-2750 (Telephone) 

(361) 575-8454 (Telefax) 

Email: 

Lamvictoriacounty@gmail.com 

Luis A. · artinez 

State Bar No. 2401021 
CERTIFICATE OF SERVICE 

This is to certify that a true, correct and complete copy of the 

foregoing instrument has been served the attorney( s) in this cause on the 9th 

day of March, 2015. 

Via Email: 

THE HON. ROB LASSMAN 

Attorney for Appellee (On Appeal) 

De Witt County Assistant District Attorney 

De Witt County Courthouse 

115 N. Gonzalez 

Cuero, Texas 77954 
THE STATE OF TEXAS 

COUNTY OF \J ;c\-o;l l\ 

VERIFICATION 

§ 

§ 

§ 

BEFORE ME, the undersigned Notary Public, on this day personally 

appeared LUIS A. MARTINEZ, who being by me duly sworn, on his oath deposed 

and said that he is the attorney in the above-entitled and numbered cause of action 

and has read the forgoing motion, and the facts stated therein are within his 

personal knowledge and are true and corr ct. 

SUBSCRIBED AND SWORN TO BEFORE ME, on the q~ day of 

N\liCJ\. , 2015_, to certify which witness my hand and official seal. 

e BRIE HANCHm . .i'f:t~ 

No:ry Publlc, Stele of Texas i 

Y Commleslon Expires JULY 80, 2018 

NOTARY P :C in and for the 

STATE OF TEXAS