CAUSE NO. 01-14-00496-CR 

STATE OF TEXAS § IN THE COURT 

VS. § OF CRIMINAL APPEALS 

PATRICK HURD § OF TEXAS 

MOTION TO EXTEND TIME TO FILE 

PETITION FOR DISCRETIONARY REVIEW 

TO THE HONORABLE JUDGES OF SAID COURT: 

Now comes PATRICK HURD, appellant in the above - styled 

and numbered cause, and moves for an extension of time 

of 30 days to file a petition for discretionary review, 

and for good cause shows the following: 

I.

This case is on appeal from the 1st Court of Appeals 

in Cause No. 01-14-00496-CR, Styled V. PATRICK HURD V. 

the STATE OF TEXAS. 

II.

The original case below was from the 155th Judicial 

District Court of Austin County, Texas and was styled 

the STATE OF TEXAS V. PATRICK HURD and numbered 2013R0086. 

PD-1281-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 9/25/2015 11:58:22 PM

Accepted 9/30/2015 1:10:58 PM

ABEL ACOSTA

CLERK
III. 

Appellant was found guilty of burglary of a building 

(enhanced to 2 nd degree) by a jury. Sentence was imposed 

at fifteen years in the Institutional Division of the 

Texas Department of Criminal Justice on July 31, 2013 

by the Honorable Jeff Steinhauser, Judge in the 155th 

District Court and was styled the STATE OF TEXAS V. 

PATRICK HURD and numbered 2013R-0086. 

IV.

Appeal was had to the First Court of Appeals. 

On August 20, 2015, the First Court of Appeals 

affirmed appellant's conviction in the above cause. 

The Petition for Discretionary Review was therefore 

due on September 20, 2015. This is appellant's first 

request to extend the time of filing of his Petition 

for Discretionary Review. 

V.

Appellant's counsel now requests an extension of 

time of 30 days from the date the PDR was due to October 

20, 2015, for reasons that follow. 
VI.

Counsel has been unable to complete Appellant's PDR 

within the required time period. Appellant relies on 

the following facts as good cause for his requested 

extension of the time for filing: 

VII.

Counsel is a solo practitioner, under contract for 

all services criminal and juvenile services in Austin 

County(with two other attorneys). Further, counsel has 

been set in the following court matters in the courts 

indicated since the time the PDR was due: 

8-25-15-ACD-PRESSWOOD,MADISON,GARZA,TESAR,WALLACE, 

D-CAMACHO,HOES,MOORE 

8-27-15-ACCL-HILL, JONES 

8-31-15-ACD-PICKRON TRIAL (MURDER CASE) 

9-8-15-ACD-TARVER, 

9-10-15-ACCL-CAMPBELL,THORPE,OLVERA 

9-11-15-WCD-HOUSTON-SENT-HRG 

9-17-15-ACCL-THOMAS 
Further, counsel was or is set in the following 

proceeding from said due date to the requested extension 

date. 

9-21-15-WCJP-ONE-CUTBIRTH 

9-22-15-ACD-WARD,CASTRO,GALLEGOS,PENRICE, 

CAMPBELL, ANDRUS 

9-24-15-ACCL-THOMAS, HARRIS 

ACCL-MCANDREWS-CUSTODY HRG 

10-7-15-WCCL-STAMPS,PRIDGETT 

10-13-15-ACD-PT-PICKRON,BLUNTSON,BATES,COOK,NELSON, 

PRESSWOOD,TARVER TR-11215 

Moreover, appellant's counsel has PDR due on 

September 28, 2015 in Cause No. 01-14-00431-CR, Styled 

: Marianne Marek V. State. Further, appellant's counsel 

has PDR due on October 5, 2015 Appeals in Cause NO. 

03-13-00595-CR, Styled : Joseph Edward McKenzie V. 

State. 

WCD506 - WALLER COUNTY 506TH DISTRICT COURT 

ACD - AUSTIN COUNTY 155TH DISTRICT COURT 

ACCL - AUSTIN COUNTY COURT AT LAW 

WCJP-ONE - WALLER COUNTY JUSTICE OF THE PEACE ONE 
WHEREFORE, PREMISES CONSIDERED, appellant respectfully requests an extension of 30 days from the due date 

to file his petition for discretionary review. 

Respectfully submitted, 

CALVIN GARVIE 

POST OFFICE BOX 416 

BELLVILLE, TEXAS 77418 

(979) 865 - 5456 

BY:/s/ Calvin Garvie 

CALVIN GARVIE 

STATE BAR NO.:07714300 

TExATTYcG@AoL.com 

ATTORNEY FOR DEFENDANT 

CERTIFICATE OF SERVICE 

I hereby certify that a true copy of this extensi on 

request was delivered or sent to the offices of t he 

Austin County District Attorney, One East Main, 

Bellville, Texas 77418 and the State Prosecuting 

Attorney, P.O. Box 12405, Austin, Texas 78711 on 

September 25, 2015 by e-mail or fax. 

BY:/s/ Calvin Garvie 

CALVIN GARVIE 
4**, DEBBIE K. MCCOSLIN 

1 MY COMMISSION EXPIRES 

4i October 20,2016 I • 

STATE OF TEXAS 

COUNTY OF AUSTIN 

§ 

§ 

§ 

AFFIDAVIT 

BEFORE ME, the undersigned authority, on this day 

personally appeared CALVIN GARVIE, who after being duly 

sworn stated: 

"I am the attorney for the appellant in the 

above numbered and entitled cause. I have read 

the foregoing MOTION TO EXTEND TIME TO FILE 

PETITION FOR DISCRETIONARY REVIEW and swear 

that all of the allegations of fact contained 

therein are true and correct to t e best of my 

knowledge." 

CALVIN GARVIE 

Affiant 

SUBSCRIBED AND SWORN TO BEFORE ME on 

September 25, 2015, to certify which witness my hand and 

seal of office. 

AO-W-(1G K 70 eC,94-6(4- 

Notary Public, State of Texas