Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 3/3/2015 9:14:56 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00701-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/3/2015 9:14:56 AM CHRISTOPHER PRINE CLERK I N THE C OURT OF A PPEALS FOR THE
F OURTEENTH D ISTRICT C OURT OF A PPEALS
H OUSTON , T EXAS
N O .
F RELIN O RELLANA
A PPELLANT On Appeal from Cause Number 1397962
From the 177 District Court V.
T HE TATE OF T EXAS
A PPELLEE
PPELLANT ’ S FINAL M OTION FOR E XTENSION
FOR 14 DAYS D UE TO E XCEPTIONAL C IRCUMSTANCES
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF
APPEALS:
COMES NOW, Frelin Orellana, and files this Motion to Extend Time to File Brief, and
in support thereof, would respectfully show the Court the following:
I.
The current deadline for filing Appellant’s Brief is March 2, 2015. There have been
three previous motions for extension of time to file Appellant’s Brief.
II.
Counsel apologizes for the delay and humbly requests this final extension of fourteen
days. Counsel had expected the brief in this case to have been completed at this time.
However, counsel has recently experienced a disruption in her work schedule due to a
painful chronic illness. Additionally, counsel’s child was ill which resulted in further
delay. Further, counsel has been engaged in work in the Harris County Public
Defender’s Office on many cases, including the following: Lenin Lopez, 01-13-01079-CR, reversed and set for retrial in cause #1403196
Vincent William, #1420283
Darryle Robertson, 14-15-00132-CR
Rodney Robins, 01-14-00582-CR
Craig Beal, 01-12-00896-CR
Abner Washington, 01-14-00885-CR
Forest Penton, 14-14-00406-CR
Leonard Storemski, 14-14-00920-CR
Norma Clark, PD-0172-15
Felix Irizarry, 14-14-00827-CR
Eddie Aldape, 14-14-00996-CR
Leslie Markle,
Dozens of writs of habeas corpus regarding the online solicitation of a minor
act being declared unconstitutional Counsel has been researching and writing for several trial cases assigned to the
Public Defender’s Office Trial Division.
III.
Appellant’s attorney requests this extension which is necessary so that the brief can be
thoroughly written and timely filed. This motion is not made for the purpose of delay. *3 PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable
Court grants this extension of the time for filing Appellant’s brief and extends the
deadline by 14 days, to March 17, 2015.
Respectfully Submitted, LEXANDER B UNIN Chief Public Defender Harris County, Texas /s/ Sarah V. Wood ARAH V. W OOD Assistant Public Defender Texas Bar Number 24048898 1201 Franklin, 13 Floor Houston, Texas 77002 Phone: (713) 368-0016 Fax: (713) 368-9278 Sarah.Wood@pdo.hctx.net CERTIFICATE OF SERVICE
By my signature below, I hereby certify that a true and correct copy of the above and
foregoing has been served upon the Harris County District Attorney's Office – Alan
Curry, via the electronic filing service.
/s/ Sarah V. Wood Sarah V. Wood