PD-0052-15 PD-0052-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS JANUARY 20, 2015 Transmitted 1/13/2015 1:10:01 PM Accepted 1/20/2015 5:22:50 PM ABEL ACOSTA NO. __________________ CLERK JULIA RHOTON ANDREWS § IN THE COURT OF § VS. § CRIMINAL APPEALS § STATE OF TEXAS § OF TEXAS MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT: Now comes Julia Rhoton Andrews, Appellant in the above styled and numbered cause, and moves for an extension of time of 30 days to file a petition for discretionary review, and for good cause shows the following: 1. On December 10, 2014, the Court of Appeals affirmed appellant's conviction. Julia Rhoton Andrews v. State, 09-13-00407-CR.

This petition is therefore due on January 10, 2015.

2. Counsel has been unable to complete the petition for the following reasons: Counsel for Appellant has been laboring under a heavy caseload and requires more time to prepare said brief and requests more time to file said PDR.

3. Defendant is currently incarcerated.

Page -1- WHEREFORE, PREMISES CONSIDERED, appellant respectfully requests an extension of 30 days, i.e. until February 11, 2015, to file a petition for discretionary review.

Respectfully submitted, CHRISTINE R BROWN-ZETO Attorney at Law 1107 Green Avenue Orange, Texas 77630 Tel: (409) 886-8558 Fax: (409) 883-6523

By: /S/ Christine R. Brown-Zeto Christine R. Brown-Zeto State Bar No. 03102200 [email protected] Attorney for Julia Rhoton Andrews

CERTIFICATE OF SERVICE This is to certify that on January 12, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Orange County, 801 Division, Orange, Texas 77630, by mail.

/S/ Christine R. Brown-Zeto Christine R. Brown-Zeto

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