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CAUSE NO. _________________

PD-1373&1374&1375-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS 

Transmitted 10/21/2015 3:47:38 PM 

Accepted 10/21/2015 4:14:01 PM 

ABEL ACOSTA

CLERK

COURT OF CRIMINAL APPEALS 

AUSTIN, TEXAS

____________________________________________

COURT OF APPEALS NO. 14-14-00488-CR, 14-14-00489-CR, 14-14-00490-CR 

TRIAL COURT NO. 1283328-A, 1283329-A, 1283330-A

EX PARTE: KERRY JONES

____________________________________________________________________

MOTION FOR AN EXTENSION

OF TIM E TO FILE PETITION FOR DISCRETIONARY REVIEW

________________________________________________________________________

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

Petitioner, Kerry Jones, filesthis Motion for Extension of Time to File Petition 

for Discretionary Review under Tex. R. App. P. 10.1, 10.5(b), and 53.7(f). In support 

of this motion, Petitioner shows the following:

1. The Fourteenth Court of Appeals in Houston, Texas rendered its opinion and 

judgment in Ex Parte: Kerry Jones, No. 14-14-00488-CR, 14-14-00489-CR, 14-

1400490-CR on August 18, 2015, a extension of time to file motion for rehearing was 

filed on September 17, 2015, a motion for rehearing was filed on September 17, 2015 

and denied on September 22, 2015. The petition for review due date for filing is due 

on October 29, 2015.
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2. Petitioner requests an extension of time of thirty days, to November 28, 2015. 

This is Petitioner's first request for an extension of time in this case.

3. Petitioner relies on the following facts as a reasonable explanation for the 

requested extension of time:

The undersigned, was hired and is the second attorney in an appeal of a murder 

case styled The State of Texas v. Fidencio Valdez, AP-77,042 and has been working 

on this brief. He has also been working on a murder trial case styled The State of 

Texas v. Ricardo Macias, No. 20130D03635 which have taken a substantial amount 

of time. The undersigned also had to complete a brief on filed on October 8, 2015 in 

a case styled Ex Parte Arturo Ochoa-Salgado, No. 08-15-00154-CR; and is currently 

working on an appeal brief the United States Court of Appeals for the Fifth Circuit 

in a case styled The United States of America v. Sally Mena-Barraza, No. 14-51334 

due October 21, 2015. The undersigned has also been very busy with court hearings, 

client conferences and a conferences with investigators all of which have prevented 

him from writing the Petition for Review by the deadline of October 29, 2015, 

necessitating the filing of this extension request.

Therefore, Petitioner prays that this Court grant this motion for extension of 

time.
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Respectfully submitted,

/s/ James D. Lucas

JAMES D. LUCAS 

SBN 12658300

2316 Montana Avenue

El Paso, Texas 79903

Tel: (915) 532-8811

Fax: (915) 532-8807

Counsel for Petitioner 

jlucas2@elp.rr.com

CERTIFICATE OF SERVICE

I, James D. Lucas, hereby certify that on the 21

th

day of October , 2015, a true and

correct amended copy of the foregoing instrument was delivered to the below-named 

individuals by electronic means:

Jaime Esparza

District Attorney

El Paso County Courthouse

500 E. San Antonio, Room 201

El Paso, Texas 79901 

tdarnold@epcounty.com

State Prosecuting Attorney

P.O. Box 12405

Austin, Texas 78711

information@spa.texas.gov

Dated this 20

th day of October, 2015.

/s/ James D. Lucas 

JAMES D. LUCAS