Case Information
*1 PD-0665-15 & PD-0666-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 6/1/2015 12:25:08 PM Accepted 6/1/2015 3:50:59 PM ABEL ACOSTA IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK AUSTIN, TEXAS GREGORIO GUERRERO §
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VS. § CASE NOS.
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THE STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
NOW COMES, the appellant, Gregorio Guerrero, by and through his attorney Jani J. Maselli Wood, and respectfully moves the Court to grant an additional thirty days to file the petitions for discretionary review and for good cause would show:
I. Mr. Guerrero was convicted of aggravated robbery with a deadly weapon and evading arrest. In two identical unpublished opinions, his convictions were affirmed May 14, 2015 in Cause Numbers 01-13-00821-CR and 01-13-00822-CR.
II. The petitions are due on June 13, 2015. Mr. Guerrero is requesting an additional thirty days to prepare the petition until July 13, 2013.
III. Undersigned counsel has numerous deadlines in the next thirty days and has been working diligently to handle all her cases:
Filed Cases
Brief for Joe Bowden v. State , 14-14-00955-CR filed on May 28, 2015;
PDR in Joshua London v. State , PD 0480-15 filed on May 1, 2015;
Oral Argument
Oral argument at the CCA in Osmin Peraza v. State on May 20, 2015
Briefs due :
Mary Kuol v. State , 14-14-01008-CR - due June 8, 2015
Lawrence Glover v. State , 14-15-00082-CR - due June 11, 2015
Shaun Briggs v. State , 01-15-00269-CR - due June 15, 2015
Carl Lovings v. State , 14-15-00167-CR - due on June 19, 2015
Mario Dunn v. State , 14-15-00340-CR - due on June 26, 2015
CLE
Counsel will be attending Public Defender Training and the TCDLA Rusty Duncan Seminar from June 17-20, 2015
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that this Court grant an additional 30 days to file the petition for discretionary review.
Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas /s/ Jani J. Maselli Wood ___________________________________ JANI J. MASELLI WOOD State Bar No. 00791195 th 1201 Franklin Street, 13 Floor Houston, TX 77002 (713) 274-6721
Attorney for Appellant, Gregorio Guerrero CERTIFICATE OF SERVICE Pursuant to Tex. R. App. Proc. 9.5, this certifies that on June 1, 2015, a copy of the foregoing was emailed to Lisa McMinn, State Prosecuting Attorney, and the Harris County District Attorney’s Office through texfile.com at the following address: Carly Dessauer
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
Dessauer_carly@dao.hctx.net
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
/s/ Jani J. Maselli Wood ___________________________________ JANI J. MASELLI WOOD