PD-0356-15 & PD-0357-15 PD-0356&0357-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/30/2015 6:14:31 PM Accepted 3/31/2015 4:47:12 PM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS CLERK AT AUSTIN RALIEGH JORDAN, APPELLANT V. THE STATE OF TEXAS, APPELLEE NO. 01-13-00775-CR NO. 01-13-00776-CR IN THE COURT OF APPEALS FOR THE FIRST SUPREME JUDICIAL DISTRICT OF TEXAS AT HOUSTON ....................................................................................................................................

TRIAL COURT NO. 1329597 TRIAL COURT NO. 1329598 IN THE 209TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS ....................................................................................................................................

APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW Charles Hinton P.O. Box 53719 Houston, Texas 77052-3719 832-603-1330 March 31, 2015 [email protected] SBOT #09709800 Attorney for Appellant TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS: Comes now appellant, Raleigh Jordan, pursuant to TEX. R. APP. PROC.

68.2(c) and 10.5(b)(1) & (3), and moves the Court for an extension of time to file appellant's petition for discretionary review, and in support shows the following: Rule 10.5(b)(3): (A) The Court of Appeals is the First Court of Appeals in Houston.

(B) The date of the court of appeals' judgment is March 10, 2015.

(C) The case number and style of the case in the court of appeals is No. 01- 13-00775-CR and No. 01-13-00776-CR styled Raleigh Jordan v. The State of Texas.

(D) No motion for rehearing or en banc reconsideration was filed in the First Court of Appeals.

Rule 10.5(b)(1): (A) the deadline for filing is April 9, 2015.

(B) the length of the extension sought is until May 11, 2015.

(C) the facts relied upon to reasonably explain the need for an extension are: Appellant's attorney has been preparing and on March 30, 2015 filed an appellate brief in the First Court of Appeals in a capital murder appeal styled Thanh Kim Hoang vs. The State of Texas, Docket No. 01-14-00722-CR.

Appellant's attorney has been preparing for jury trial in the 209th District Court in the following cases: 1.The State of Texas vs. Curtis Babers, cause number 1299015 (sexual assault) scheduled to start March 24, 2015, but then carried until March 30, and now rescheduled for the week of April 13, 2015.

2. The State of Texas vs. Depachej Johnson, cause number 1346275 (aggravated robbery) & cause number 1307808 (Burglary of Habitation) set for April 6, 2015.

3. The State of Texas vs. Russell Loge, cause number 1181851 (Aggravated Sexual Assault of a Child) set for April 6, 2015.

4. The State of Texas vs. Harry Williams, cause number 1220865 (murder) & 1220866 (aggravated assault) set for April 13, 2015.

(D) No previous extensions have been granted.

Wherefore, undersigned counsel prays this honorable Court to extend the time for filing appellant's petition until May 11, 2015.

Respectfully submitted, /s/Charles Hinton Charles Hinton P.O. Box 53719 Houston, Texas 77052-3719 832-603-1330 [email protected] SBOT #09709800 Attorney for Appellant CERTIFICATE OF COMPLIANCE Appellant certifies that the word count of this document is 508.

/s/Charles Hinton Charles Hinton

CERTIFICATE OF SERVICE I certify that a copy of this motion has been electronically served upon Alan Curry, Chief Prosecutor, Appellate Division, Harris County District Attorney's Office, 1201 Franklin St., Ste. 600, Houston, Texas 77002 on March 30, 2015.

/s/Charles Hinton Charles Hinton