Court of Civil Appeals of Texas, 2015

Redden, Brittany

Redden, Brittany
Court of Civil Appeals of Texas · Decided September 1, 2015

Redden, Brittany

Opinion

PD-1132-15 PD-1132-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/31/2015 4:13:00 PM Accepted 9/1/2015 12:28:11 PM ABEL ACOSTA Cause Number CLERK BRITTANY REDDEN, § APPELLANT, § § IN THE TEXAS COURT VS. § § OF CRIMINAL APPEALS THE STATE OF TEXAS, § APPELLEE. §

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT: Now comes BRITTANY REDDEN, Appellant in the above styled and numbered cause, by and through her attorney of record, WM. REAGAN WYNN, and pursuant to Rules 10.5(b) and 68.2(c), Texas Rules of Appellate Procedure, files this First Motion for Extension of Time to File Petition for Discretionary Review , and for such Motion would respectfully show the Court as follows: 1. Trial Court: County Criminal Court Number Six, Tarrant County, Texas.

2. Date of Judgment and Sentence: May 15, 2013.

September 1, 2015 3. Trial Court Cause Number: 1204249.

4. Style of Cause: State of Texas v. Brittany Redden.

5. Offense For Which Appellant Was Convicted: Driving While Intoxicated.

6. Punishment Assessed: 90 days jail / 12 months probation.

7. Appellant is currently not incarcerated.

8. Notice of Appeal filed: June 13, 2013.

9. Court of Appeals: Eleventh Court of Appeals.

10. Style of Cause in Court of Appeals: Brittany Redden v. The State of Texas.

11. Court of Appeals’ Cause Number: 11-13-00214-CR.

12. Date Court of Appeals’ Judgment and Opinion Entered: July 30, 2015.

13. Date Motion for Rehearing Filed: n/a.

14. Date Motion for Rehearing Overruled: n/a.

15. Current Due Date for Petition for Discretionary Review: August 31, 2015.

16. Length of Time Requested for Extension: 30 days, to September 30, 2015.

17. Number of Prior Extensions of Time: 0.

18. The facts relied upon to reasonably explain the need for an extension: a. Undersigned counsel is preparing to file the Petition for Discretionary Review in the matter of Timothy Edward Whitington v. The State of Texas, Texas Court of Appeals Cause Number 08-13-00102-CR.

b. This extension is not requested for the purposes of delay, but so that justice may be done and undersigned counsel may effectively represent Appellant in this matter.

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW Page 2— WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court will extend the time within which to file the Petition for Discretionary Review until the 30th day of September, 2015.

Respectfully submitted,

/s/ Wm. Reagan Wynn WM. REAGAN WYNN State Bar Number: 00797708 [email protected] KEARNEY | WYNN One Museum Place 3100 West 7th Street, Suite 420 Fort Worth, Texas 76l07 (8l7) 336-5600 (817) 336-5610 (fax) CERTIFICATE OF CONFERENCE On August 31, 2015, conference was held with Cyndi Burgess of the Tarrant County District Attorney’s office and indicated the State has no objection to an extension of time.

/s/ Wm. Reagan Wynn WM. REAGAN WYNN

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW Page 3— CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been delivered to the office of Jim Gibson of the Appellate Section of the Tarrant County District Attorney via email on the 31st day of August, 2015.

/s/ Wm. Reagan Wynn WM. REAGAN WYNN

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW Page 4—

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