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 S13-3012-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

CLERK
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Now comes Remus Litoiu, Appellant, and moves this Court to grant an 

extension of 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 appeal from the 36th Judicial District Court of San Patricio 

County, Texas.

2. The style of the case in the 13th 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 Court of Appeals was given 

on July 30, 2015.

4. The appellate Petition for Discretionary Review is presently due on August 

31, 2015.

5. Appellant requests an extension of time of 15 days from the present due 

date, i.e. August 31, 2015, to file his Petition for Discretionary 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.
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8. Appellant 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 15-day extension to properly 

complete the Petition. Appellate Counsel’s paralegal, Alice Sheets, was out of the office 

during the week of August 24 – 28, 2015, while under subpoena in a case pending in the 

214th Judicial District Court in Nueces County, in which she was a testifying witness. 

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 appropriate Petition for Discretionary 

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.
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CERTIFICATE 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 31st day of August 2015, on the following:

Via Fax 361-364-9490 

San Patricio District Attorney

400 West Sinton Street, Room 108

Sinton, Texas 78387

_/s/ Les Cassidy _________________

Les Cassidy