*1 PD-0291-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/16/2015 11:08:26 PM Accepted 3/18/2015 4:19:54 PM ABEL ACOSTA CLERK PD-__________-15

In the Court of Criminal Appeals of Texas

Leroy Calhoun, Jr.

v.

The State of Texas Motion to Extend Time to File

Petition for Discretionary Review Leroy Calhoun moves, under Rule 68.2, to extend the time to file a petition for discretionary review (PDR).

On February 12, 2015, the Tenth Court of Appeals a ffi rmed the judgment of the trial court in a memorandum opinion, under cause number 10-14-00058-CR.

No previous extensions to file a PDR have been requested. The current deadline is March 16, 2015.

Mr. Calhoun requests an additional 60 days to file the petition, making the new due date May 15, 2015. Counsel was hired on this case after appointed counsel declined to file a PDR, and needs additional time to review the record, familiarize himself with the case, and complete the petition.

In addition, counsel has been occupied with preparing for the motion for new trial hearing in Pete Rodriguez v. State, 01-15- 00135-CR; writing and filing the brief in Jesus Jimenez v. United States in the United States Court of Appeals for the Fifth Cir- cuit; and preparing the motion for new trial in Pastor Israel Diaz v. State, no cause number yet assigned.

I served a copy of this motion on the State of Texas simultane- ously with electronic filing.

Respectfully, ____________________ Bynum Law Office Franklin Bynum

2814 Hamilton Street Texas Bar Number 24069451 Houston, Texas 77004 fgb@lawfgb.com

(713) 343-8844

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