PD-1286-15 PD-1286-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/28/2015 2:48:25 PM Accepted 9/30/2015 2:03:37 PM ABEL ACOSTA PDR No. ____________________ CLERK Court of Appeals No. 03-13-00804-CR KAITLYN RICHERSON § 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 KAITLYN RITCHERSON, Petitioner in the above styled and numbered cause, and moves this Court for a 90-day extension to file her Petition for Discretionary Review, and would show as follows: 1. Petitioner has been convicted for the offense of Murder and has been assessed a sentence of 25 years.

2. The Third District Court of Appeals issued an published decision in this case on August 31, 2015. Kaitlyn Lucretia Ritcherson v. State of Texas, 03- 13-00804 (Tex.App.- Austin, August 31, 2015). The PDR in this case is due on or before October 1, 2015.

3. Petitioner requests an additional 90 days from the present due date to file a Petition for Discretionary Review. As good cause, Petitioner would show that the undersigned counsel is reviewing the case to determine the best issue(s) in

September 30, 2015 which to raise in a Petition for Discretionary Review. In addition to the present case, counsel has had the following appellate matters which have become due during the month of September: a. USA v. Alberto Moncivais-Almendar – appeal was filed in the 5th Circuit Court of Appeals on September 25, 2015; b. USA v. Rachel Hardy – appeal is due to be filed in the 5th Circuit Court of Appeals on September 25, 2015; and, c. State of Texas v. Preston Sharpnack – PDR was filed in this Court on or about September 10, 2015.

In addition to the foregoing, counsel will have the following appellate matters throughout the months of October and November: a. State of Texas v. Anthony Robertson– PDR is due in this Court on October 21, 2015; b. State of Texas v. Ricky Ellison – PDR is due in this Court on November 12, 2015; c. State of Texas v. Reynaldo Zamora – appeal is due in First District Court of Appeals in late October or early November 2015; d. USA v. Rickey Benns – counsel is scheduled for oral argument

before the 5th Circuit Court of Appeals in New Orleans on November 6, 2015.

e. Counsel will be out of the country on a pre-scheduled CLE from November 15 through 21, 2015.

6. Accordingly, the undersigned counsel requests this Court extend the deadline to file the PDR in this case by 90 days from the current due date.

WHEREFORE, PREMISES CONSIDERED, Petitioner prays that this Court grant this Motion, and grant an additional 90 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 Kaitlyn Lucretia Ritcherson

CERTIFICATE OF SERVICE I hereby certify that on September 28, 2015, a copy of the above and foregoing motion has been served by mail upon the Travis County District Attorney's Office, at the following address: Travis County District Attorney P.O. Box 1748 Austin, TX 78767

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

/s/ Alexander L Calhoun Alexander L. Calhoun