Case Information

*1 PD-0643-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/1/2015 10:50:06 PM Accepted 7/2/2015 3:19:43 PM ABEL ACOSTA TO THE COURT OF CRIMINAL APPEALS CLERK F ROM THE F IRST C OURT OF A PPEALS

N O . 01–14–00392–CR

C HANCE R OACH

A PPELLANT On Appeal from Cause Number 1394753

From the 185th District Court of Harris County V.

T HE S TATE OF T EXAS

A PPELLEE

Appellant’s FINAL Motion To Extend Time

To File Petition For Discretionary Review

Accompanied by PDR T O T HE H ONORABLE J UDGES O F T HE C OURT O F C RIMINAL A PPEALS :

C OMES N OW , C HANCE R OACH , and files this his Motion to Extend Time to File Petition for Discretionary Review, and in support thereof, would respectfully show the Court the following:

I. The First Court of Appeals affirmed the trial court’s judgment in Roach v. State , 01-14-00392- CR, 2015 WL 1778896 (Tex. App.—Houston [1st Dist.] Apr. 16, 2015, no. pet. h.). No motion for rehearing was filed. One other motion for extension has been filed.

II. In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for extension is timely filed within 15 days of the deadline for the PDR, which was June 17, 2015. Appellant requests this extension due to the fact that counsel for Appellant has been ill as has other family members and additionally has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:

 Ruben Totten, PD-0483-15

 Bobby Easley, PD-0468-15

 Hugo Pachas-Luna, 01-14-00516-CR - 01-14-00520-CR

 Rodney Robins, 01-14-00582-CR

 Stephen Hopper, 14-15-00371-CR

 Pete Rodriguez, 14-15-00339-CR

 Vincent Williams, 14-15-00220-CR

 Darryle Robertson, 14-15-00132-CR

 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 brief extension which is necessary so that the petition can be thoroughly written and timely filed. This motion is not made for the purpose of delay.

PRAYER

W HEREFORE , P REMISES C ONSIDERED , Appellant prays that this Honorable Court grants this requested extension of time to file the appellant’s petition for discretionary review in the above cause and extend the time for filing to July 1, 2015, the day on which the PDR is simultaneously submitted or the official date it is deemed filed.

Respectfully submitted, A LEXANDER B UNIN Chief Public Defender Harris County, Texas /s/Sarah V. Wood S ARAH V. W OOD Assistant Public Defender Harris County, Texas Texas Bar Number 24048898 1201 Franklin, 13 th Floor Houston Texas 77002 713.368.0016 (phone) 713.368.9278 (fax) Sarah.Wood@pdo.hctx.net Attorney for Appellant C ERTIFICATE OF S ERVICE

By my signature below, I hereby certify that a true and correct copy of the above and foregoing Appellant’s Motion to Extend Time to File Petition for Discretionary Review has been served on the District Attorney of Harris County, Texas, by electronic delivery through the efile system.

/s/Sarah V. Wood

Sarah V. Wood