NO. PD.________________

______________________________________________ ___________________ IN THE COURT OF CRIMINAL APPEALS OF TEXAS

REMUS LITOIU, APPELLANT
V. THE STATE OF TEXAS, APPELLEE

________________________________________________________________ __ On Petition For Discretionary Review From The Thirteenth Court Of Appeals In No. 13

- 13

- 00489

- CR affirming the conviction in cause number S

13

- 3012

- Cr, from the District Court Of San Patricio County, Texas

APPELLANT’S MOTION FOR EXTENSION OF TIME Respectfully submitted , /s/ Les Cassidy Les Cassidy 814 Leopard Street Corpus Christi, Texas 78401 361

- 887

- 2965 (office) 361

- 885

- 0320 (fax) State Bar No. 03979270 Attorney for Appellant, REMUS LITOIU

______________________________________________ ____________________ PD-1131-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 8/31/2015 3:41:33 PM Accepted 9/1/2015 12:06:29 PM

ABEL ACOSTA CLERK2 Now comes Remu s Litoiu , Appellant , and moves this Court to grant an
extension o f time to file appellant's Petition for Discretionary Review , pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following:

1. This case was on app eal from the 36th Judicial District Court of San Patricio County, Texas.

2. The style of the case in the 13 th Court of Appeals was REMUS LITOIU vs. STATE OF TEXAS , and numbered 13

- 13

- 00489

- CR.

3

. Notice of the Opinion and Judgment from the C ourt of Appea ls was given on July 30, 2015

.
4

. The appellate Petition for Discretionary Review is presently due on August 31, 2015

.

5. Appellant re quests an extension of time of 1 5 days from the present due date, i.e. August 31, 2015, to file his Petition for Discret ionary Review.

6

. This Motion is timely filed less than 15 days after the last day for filing a Petition for Discretionary Review

.

7

. No prior extensions to file the appellant’s Petition for Discretionary Review have been requested in this cause.3 8

. App ellant relies on the following facts as good cause for the requested
extension:

Counsel needs additional time to adequately prepare the Appellant's Petition for Discretionary Review for filing and Counsel is asking for a 1 5

- day extension to pro perly

com plete the Petition

. Appellate Counsel’s paralegal, Alice Shee ts, was out o f the office during the week of August 24

– 28, 2015 , while under subpoena in a case pending in the
214 th Judicial District Court in Nueces County, in which she was a testifying witn ess. Appellate counsel has multiple trial settings in District and County Courts and will be busy resolving two matters on August 31, 2015 through September 2, 2015. A 15

- day extension will allow more time for the filing of an appr opriate Petition for Disc retionary
Review.
WHEREFORE, PREMISES CONSIDERED , Appellant prays that this Court grant this Motion for Extension of Time to File Appellant's Petition for Discretionary
Review , and for such other and further relief as the Court may deem appropriate.4 CE RTIFICATE OF SERVICE I certify that a true copy of the above was served in accordance with the Texas Rules of Civil Procedure on this the 31 st day of August 2015 , on the following:

Via Fax 361

- 364

- 9490 San Patricio District Attorney 400 West Sinton Str eet, Room 108 Sinton, Texas 78387

_ /s/ Les Cassidy

_______ __________ Les Cassidy