PD-0048-15 COURT OF CRIMINAL APPEALS

JANUARY 16, 2015 PD-0048-15 AUSTIN, TEXAS Transmitted 1/12/2015 3:15:54 PM Accepted 1/16/2015 4:57:13 PM IN THE COURT OF APPEALS ABEL ACOSTA ELEVENTH DISTRICT OE TEXAS CLERK

KIM FINLEY § 11-13-00050-CK § vs. § § § STATE OF TEXAS §

APPELLANT'S MOTION TO EXTEND TIME

TO THE HONORABLE JUDGE OF THE SAID COURT,

Comes now. Appellant, Kim Finlcy, and files this Motion to Extend Time and would

show the following:

1. The Appellant's Petition for Discretionary Review is due January 12, 2(115.

Appellant respectfully requests an extension until March 13, 2015 to file her petition.

Counsel for Appellant was engaged in a murder trial (State of Texas v. Lavhvla

Schoonover, Tarrant County Cause Number 1338474) when the Memorandum Judgment

was issued, thus delaying communication to the incarcerated client.

2. Appellant will exercise diligence to ensure that this Petition will be filed at the

earliest practicable time.

WHEREFORE, premises considered, the Appellant respectfully asks this Court to

grant this extension pursuant to Tex. R. App. P. (i8.2(c).

Respectfully submitted,

Scott, McNeill & Burney, PLLC 3000 East U)op82() Ft Worth, Texas 76112 (817)534-8000 (817) 851-1404 fax By: /s/ Mark D. Scott_

Mark D. Scott State Bar No. 24043911 Attorney Tor Appellant

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 by facsimile to

(817)884-1672.

_/s/ Mark D. Scott Mark D. Scott Stale Bar No. 24043911 Attorney for Appellant 3000 East Loop 820 Ft Worth, Texas 76112 (817)534-8000 (817)851-1404 fax markscottlaw(«;yahoo.com

CERTIFICATE OF CONFERENCE

Prior to presenting this matter to the Court for Approval, I contacted Alice

London, of the Tarrant County District Attorney's Office Appellate Section via telephone

on 1/12/15. Ms. London slated that the Tarrant County District Attorney's Office had no

objection to this motion.

_/s/ Mark D. Scott

Mark D. Scott 3000 Fast Loop 820 Ft Worth Texas 76112 (817)534-8000 (817) 85 1-1404 fax markscottlaw(«;yahoo.com State Bar No. 24043911