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

CLERKrobberies and assault on public servant’s in the 411 th 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

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

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

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

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 certif y 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 PawganCourt 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

ORD ER 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.

I T 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 _____________________.

____________________________ Judg e, Court of Criminal Appeals