Case Information

*1 PD-0995-15, PD-0996-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/31/2015 9:49:31 PM Accepted 8/6/2015 9:40:31 AM ABEL ACOSTA CLERK No. ________

__________________________________________

IN THE

TEXAS COURT OF CRIMINAL APPEALS

__________________________________________

KENNETH TURNER,

Petitioner ,

V .

STATE OF TEXAS,

Respondent . __________________________________________________________________

FIRST MOTION FOR EXTENSION OF TIME

TO FILE PETITION FOR REVIEW __________________________________________________________________ TO THE HONORABLE COURT OF CRIMINAL APPEALS:

Petitioner files this First Unopposed Motion for Extension of Time to File Petition for Discretionary Review under Tex. R. App. P. 10.5(b) and 68.2(c). In support of this motion, Petitioner shows the following:

I. The Court of Appeals for the Fifth District in Dallas rendered its opinion and judgment in Kenneth Turner vs. The State of Texas, No: 05-13- 01486 CR and No: 05-13-01487 CR, on October 29, 2014. Petitioner timely *2 filed his Motion for Rehearing and the Court of Appeals for the Fifth District in Dallas rendered its opinion affirming the judgment on December 19, 2014. Petitioner timely filed his Motion for En Banc Reconsideration and the Court of Appeals affirmed the judgment on June 16, 2015. The Petition for Discretionary Review was due no later than July 16, 2015.

II. Petitioner requests an extension of time of thirty days, to August 30, 2015. This is Petitioner’s first request for an extension of time in this case.

III. Petitioner relies on the following facts as a reasonable explanation for the requested extension of time. Petitioner’s counsel, request an extension in order to adequately brief the complex legal issues presented by this appeal

IV. WHEREFORE, PREMISES CONSIDERED, Petitioner prays that this Court grant this motion for extension of time

Respectfully Submitted, /s/ Darian Howard DARIAN HOWARD SBN: 24067669 P.O. Box 411252 Dallas, Texas 75241 (972)437.3801 (Telephone) (972)437.3139 (Facsimile) ATTORNEY FOR KENNETH TURNER CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing instrument has been served electronically on the Dallas County District Attorney on this the 31 st day of July 2015.

/s/ Darian Howard Darian Howard