PD-0998-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS AUGUST 6, 2015 Transmitted 8/3/2015 12:00:00 AM Accepted 8/6/2015 10:22:00 AM PD-0998-15 PDR No. ____________________ ABEL ACOSTA CLERK Court of Appeals No. 03-13-00381-CR ANTHONY BOYD ROBERTSON § IN THE TEXAS COURT OF § v. § CRIMINAL APPEALS § STATE OF TEXAS § AT AUSTIN, TEXAS PETITIONER’S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUSTICES OF SAID COURT: Now comes ANTHONY BOYD ROBERTSON, Petitioner in the above styled and numbered cause, and moves this Court for a 60-day extension to file his Petition for Discretionary Review, and would show as follows: 1. Petitioner has been convicted for the offense Assault with Bodily Injury – Family Violence (Repeat Offender), and has been assessed sentence of 14 years.

2. The Third District Court of Appeals issued an unpublished decision in this case on July 23, 2015. Anthony Boyd Robertson v. State of Texas, 03-13-00381 (Tex.App.- Austin, July 23, 2015). The PDR in this case is due on or before August 24, 2015.

3. The undersigned counsel is appointed and his appointment has terminated following the decision in this case. Nevertheless, counsel believes the

opinion by the Court of Appeals has potential issues for a Petition for Discretionary Review. Counsel has advised Petitioner by letter on this date regarding the potential issues, as well as the status of his representation.

4. In order to preserve Petitioner’s right to file a Petition for Discretionary Review, counsel intends to meet with the trial court on the week of August 3 to determine whether appellate representation will continue. Due to the presence of impending trial deadlines in August/September and a Reply Brief due in federal court relating to a death penalty case, Counsel requires extra time to prepare a PDR.

5. In the alternative, if the trial court does not continue the undersigned counsel’s representation, Petitioner needs time to retain counsel, or to obtain the record and other necessary documents in which to prepare a PDR,.

6. Accordingly, te undersigned counsel requests this Court extend the deadline to file the PDR in this case by 60 days from the current due date.

5. Mr. Robertson’s personal information for the purposes of notices by this Court is as follows: Mr. Anthony Boyd Robertson # 01863976 TDC Jordan Unit 1992 Helton Road Pampa, TX 79065

WHEREFORE, PREMISES CONSIDERED, Petitioner prays that this Court grant this Motion, and grant an additional 60 days to file a PDR in this case Respectfully submitted, Law Office of Alexander L. Calhoun 4301 W. William Cannon Dr., Ste. B-150, # 260 Austin, TX 78749 Tele: 512/ 420-8850 Fax: 512/ 233 - 5946 Cell: 512/ 731-3159 Email: [email protected] BY:_/s/ Alexander L Calhoun Alexander L. Calhoun State Bar No.: 00787187 Attorney for Anthony Boyd Robertson

CERTIFICATE OF SERVICE I hereby certify that on July 30, 2015, a copy of the above and foregoing motion has been served by mail upon the Hays County District Attorney's Office, at the following address: Hays County District Attorney Hays County Government Center South Stagecoach Trail, Ste. 2507 San Marcos, TX 78666. upon the State Prosecution Attorney by U.S. Mail at the following address:

State Prosecuting Attorney P.O. Box 13046 Capitol Station Austin, Texas 78711 and upon Appellant by U.S. Mail to the following address: Mr. Anthony Boyd Robertson # 01863976 TDC Jordan Unit 1992 Helton Road Pampa, TX 79065

/s/ Alexander L Calhoun Alexander L. Calhoun