Court of Criminal Appeals No. _______________ 

Appeal No. 01-13-00295-CR

Trial Cause No. 12-08-08659-CR

EDWARD FLORES § IN THE COURT OF CRIMINAL

§

VS. § APPEALS

§

STATE OF TEXAS § AUSTIN, TEXAS 

MOTION FOR EXTENSION OF TIME TO FILE 

PETITION FOR DISCRETIONARY REVIEW 

TO THE HONORABLE JUDGES OF SAID COURT: 

 COMES NOW, Edward Flores, Appellant, and requests this Court grant an 

extension of time to file his Petition for discretionary review and would show unto the 

Court the following: 

 1. On February 26, 2015, the Court of Appeals delivered and filed its opinion 

in Appeal No. 01-13-00295-CR, styled Edward Flores v. State of Texas, in the First 

Court of Appeals in Houston, Texas. 

 2. The deadline for filing a petition for discretionary review is March 30, 

2015.1. The Deadline for filing a motion for extension of deadline to file Petition for 

Discretionary review pursuant to Texas Rule of Appellant Procedure 68.2(c) is April 15, 

2015. 

 3. Appellant is requesting an extension of at least sixty days. 

4. Appellant's counsel is requesting this extension of time to his motion to 

file Appellant's Brief because Appellant's Counsel was set for Jury on March 2, 2015 on 

an Aggravated Robbery, Aggravated Kidnapping and unadjudicated Aggravated 

 

1

 The actual due date to file the motion for rehearing is March 28, 2015. Since March 28, 2015 is a 

Saturday, the due date would be moved to the first business day, which would be March 30, 2015. T.R.A.P 

4.1(a) 

PD-0349-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 3/30/2015 3:05:38 PM

Accepted 3/31/2015 2:53:09 PM

ABEL ACOSTA

CLERK
robberies and assault on public servant’s in the 411th Judicial District Court of Polk 

County. That Polk County case plead only the Friday before jury selection was to start. 

Counsel was also in Jury trial the week of March 9, 2015 in a Habitual first degree 

delivery of a controlled substance in the 75th Judicial District Court of Liberty County, 

Texas. Finally, Appellant Counsel is beginning jury trial, March 30, 2015 in the 258th

Judicial District Court of Polk County, on an Aggravated robbery case that has 16 media 

disks, over 6000 pages in medical records, and over 500 pages in police and Texas Ranger 

reports.

5. No other extensions for time to file an extension to file Petition of 

Discretionary Review have been previously granted to this attorney in this appeal.

Respectfully Submitted,

_______________________________

Scott Pawgan

State Bar No. 24002739

122 W. Davis, Ste 116

Conroe, Texas 77301

Phone (936) 242-6975

Fax (800) 619-5113

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing was served upon the attorney 

for the State via the electronic service feature of the e-file provider this motion was filed 

with on the March 30, 2015.

___________________________________

Scott Pawgan
Court of Criminal Appeals No. _______________

Appeal No. 01-13-00295-CR

Trial Cause No. 20795

EDWARD FLORES § IN THE COURT OF CRIMINAL

§

VS. § APPEALS

§

STATE OF TEXAS § AUSTIN, TEXAS 

ORDER ON MOTION FOR EXTENSION OF TIME 

TO FILE PETITION FOR DISCRETIONARY REVIEW

On this day came to be heard Appellant’s Motion For Extension Of Time To File 

Petition For Discretionary Review and the Court is of the opinion the motion should be 

GRANTED.

IT IS ORDERED that Appellant’s deadline to file Appellant’s Petition for 

Discretionary review be extended from April 8, 2011 and Appellant’s Petition for 

Discretionary Review is now due _____________________.

____________________________

Judge, Court of Criminal Appeals