*1 PD-1315-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 10/5/2015 3:30:30 PM Accepted 10/7/2015 3:00:53 PM ABEL ACOSTA CAUSE NO. 07-13-280- CR CLERK TERESA AGUILERA § IN THE COURT OF

§ v. § CRIMINAL APPEALS

§ STATE OF TEXAS § OF TEXAS

MOTION TO EXTEND THE TIME TO FILE THE

PDR CONTEMPORANEOUSLY SUBMITTED

WITH THIS MOTION

TO THE HONORABLE JUDGES OF THE

COURT OF CRIMINAL APPEALS:

COMES NOW Teresa Aguilera, Petitioner, and files this motion to extend the time to file the PDR to October 5, 2015, the date of its e-filing.

I. The court of appeals’ ruling was issued on July 30, 2015, and the order denying rehearing on September 1, 2015, making the PDR due October 1, 2015. No prior extension motion has been filed.

II. The reason for this request is as follows. On September 29, 2015, undersigned counsel has very recently finished and filed a very long and involved opening brief in Martin v. State, 07-15-00079-CR, and until now has not had time to prepare the PDR.

WHEREFORE, the Petitioner prays the Court grant an extension of time to file her PDR to October 5, 2015, the date the PDR is electronically filed.

Respectfully submitted, /s JOHN BENNETT

John Bennett

Post Office Box 19144 Amarillo, Texas 79114 (806) 282-4455

Fax: (806) 398-1988

State Bar Number 00785691 Email: AppealsAttorney@gmail.com Attorney for the petitioner CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above Motion has been served on Richard Martindale, Esq., by personal delivery, and on Lisa McMinn, Esq., State Prosecuting Attorney, by email to her at lisa.mcminn@spa.texas.gov, both on October 5, 2015.

/s JOHN BENNETT

John Bennett

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