Palmer, William Gerard ( 2015 )

PD-1624-15 PD-1624-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/15/2015 4:10:58 PM Accepted 12/15/2015 4:41:01 PM ABEL ACOSTA NO. CLERK IN THE COURT OF December 15, 2015 CRIMINAL APPEALS OF TEXAS WILLIAM GERARD PALMER, PETITIONER VS. THE STATE OF TEXAS, RESPONDENT MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT: Appellant herein, WILLIAM GERARD PALMER, by and through his attorney of record, makes this Motion for Extension of Time to File Petitioner’s Petition for Discretionary Review, pursuant to Rule 68.2(c), TEX. R. APP. PROC., and as grounds therefore would show the Court: I. Petitioner’s conviction was affirmed by the Court of Appeals for the Fifth District of Texas, on November 9, 2015 in Cause No. 05-14-00671, styled William Gerard Palmer, Appellant v. The State of Texas, Appellee.. II. Appellant was convicted of capital murder and assessed a sentence of life confinement in the Texas Department of Criminal Justice, without possibility of parole. III. Petitioner’s petition for discretionary review was due to be filed on December 9, 2015. Petitioner requests an extension of time to file his petition, for the reasons set out below The Court has granted no previous extensions to file Petitioner’s petition. IV. The length of time requested for the extension is six (6) days or until December 15, 2015. V. Good cause for the requested extension exists because counsel for Petitioner is old and slow to learn new things. He has sent an original hard copy of his Petition for Discretionary Review, with eleven (11) copies, to this Honorable Court for filing, but learns that, once again, he is behind the times and must file electronically. Petitioner has electronically filed his Petition, as required.. WHEREFORE, PREMISES CONSIDERED, Petitioner, by and through his attorney of record prays that the Court will grant this Motion and extend the time for filing Petitioner’s Petition for Discretionary Review to December 15, 2015. Respectfully submitted, /s/ Douglas H. Parks DOUGLAS H. PARKS State Bar No. 15520000 321 Calm Water Lane Holly Lake Ranch, Texas 75765 (903) 769-3120 (903) 769-3465 - Fax CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion for Extension of Time to File Petitioner’s Petition for Discretionary Review was served on the District Attorney of Dallas County, Texas on the 15th day of December, 2015, by email. /s/ Douglas H. Parks DOUGLAS H. PARKS