Case Information
*1 PD-0477-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 5/26/2015 5:30:38 PM Accepted 5/28/2015 2:35:56 PM No. PD-0477-15 ABELAp?!IJ In the
Court of Criminal Appeals At Austin ^CdsZ^ -♦- No. 01-13-00991-CR *+0 U'^ - I 'V In the c Court of Appeals for the
First District of Texas at Houston No. 1315240 In the 176th District Court Harris County, Texas JOSE FRANCO CAMPUZANO Appellant
V. THE STATE OF TEXAS Appellee
APPELLANT'S SECOND MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE PETITION FOR DISCRETIONARY REVIEW FILED IN
COURT OF CRIMINAL APPEALS
May 28, 2015
ABEL ACOSTAt CLERK
TO THE HONORABLE COURT OF APPEALS:
APPELLANT, pursuant to Tex. R. APP. P. 68.2(c) moves for an extension of time within which to file its petition for discretionary review. In support of its motion, appellant submits the following:
1. Appellant was charged with the felony offense of intoxication assault.
2. A jury convicted appellant of the charged offenses and sentenced him to
5 years community supervision on October 15, 2013. 3. A unanimous panel of the First Court of Appeals rendered judgment in
an unpublished opinion on March 26, 2015, affirming appellant's conviction and sentence.
4. After one extension was granted, appellant's petition for discretionary
review is due on May 26, 2015. 5. Appellant seeks a short extension, in accordance with TEX. R. APP. P.
68.2(c), untilJune 2, 2015, to file its petition for discretionary review. 6. The following facts are relied upon to show good cause for the
requested extension:
a. Counsel has been delayed in completing the petition due to the
recent flooding in the Houston area on May 24, 2015. High water resulted in school closures, as well as counsel's inability to travel into the city to her office to complete the petition.
b. Appellant's petition is not for purposes of delay, but so that justice may
be done. *3 WHEREFORE, the Appellant prays that this Court will grant the requested extension until June 2, 2015.
Respectfully submitted, /s/Mandy Miller Attorney for appellant 2910 Commercial Center Blvd., Ste. 103-201 Katy, TX 77494 SBN 24055561
PHONE (832) 900-9884 FAX (877) 904-6846 mandy@mandymiUerlegal.com CERTIFICATE OF SERVICE Pursuant to TEX. R. App. P. 9.5, this certifies that on May 25, 2015, a copy of the foregoing was delivered to the following addresses:
Melissa Hervey
Harris County District Attorney's Office
hervey melissa@dao.hctx.net
Lisa McMinn
State Prosecuting Attorney
lisa.mcminn.@spa.state.tx.us
/s/Mandy Miller