PD-1586-15

PD-1586-15 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 12/7/2015 12:00:00 AM December 7, 2015 Accepted 12/7/2015 2:33:39 PM

No. ____________________ ABEL ACOSTA

CLERK

In The

Court of Criminal Appeals

Of The State of Texas

Austin, Texas

_________________________________________

CHRISTOPHER JOSEPH CAMPOS,

Petitioner

vs.

THE STATE OF TEXAS

_________________________________________ MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY

REVIEW TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Christopher Campos, Appellant in Cause Number 09-14-00481-CR in the Ninth Court of Appeals- Beaumont, and asks this Court to permit the extension of time to file the Petition for Discretionary Review, pursuant to the Texas Rules of Appellate Procedure, and for good cause shows the following:

1. Appellant hereby requests leave of the Court to extend the time to file the Petition for Discretionary Review. The current deadline was December 4, 2015. No previous extensions to file the brief have been requested or granted.

2. Undersigned counsel inadvertently miscalculated the deadline to file the Petition (or the motion to extend), and respectfully requests that the Court grant this extension and allow counsel to file the petition on Monday, December 7, 2015, in the interest of justice for Appellant Christopher Campos.

3. Undersigned counsel respectfully requests a 30 day extension of the deadline but will nevertheless file the Petition for Discretionary Review on Monday, December 7, unless instructed otherwise by the Court. .

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion for Extension of Time to File the Petition for Discretionary Review and for such other and further relief as the Court may deem appropriate.

Respectfully submitted,

THE GERTZ LAW FIRM

2630 Liberty St.

Beaumont, Texas 77702

Tel: (409) 833-6400

Fax: (409) 833-6401

/s/ Ryan W. Gertz

By:

Ryan W. Gertz

State Bar No. 24048489

Attorney for Marcus James

CERTIFICATE OF SERVICE

This is to certify that on December 5, 2015, a true and correct copy of the foregoing document was served on the Jefferson County District Attorney's Office, 1001 Pearl St., 3rd Floor, Texas 77701, via e-file.

/s/ Ryan W. Gertz

Ryan W. Gertz