Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 1/12/2015 9:11:15 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-00582-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 1/12/2015 9:11:15 AM CHRISTOPHER PRINE CLERK I N THE C OURT OF A PPEALS FOR THE

F IRST D ISTRICT C OURT OF A PPEALS

H OUSTON , T EXAS

N O . 01-14-00582-CR

R ODNEY R OBINS

A PPELLANT On Appeal from Cause Number 1408007

From the 179 District Court

V.

T HE TATE OF T EXAS

A PPELLEE

PPELLANT ’ S M OTION TO E XTEND T IME TO F ILE RIEF

TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS:

COMES NOW, Rodney Robins, 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 January 2, 2015. There has been one

previous motion for extension of time to file Appellant’s Brief.

II.

Appellant requests this extension due to the fact that counsel has been engaged in work

in the Harris County Public Defender’s Office on many cases, including the following:

 Curtis Fournier, WR-82,102-01 – briefing ordered in Court of Criminal Appeals

 Christopher Dowden, WR-82,103-01– briefing ordered in Court of Criminal

Appeals

 Craig Beal, 01-12-00896-CR Abner Washington, 01-14-00885-CR Forest Penton, 14-14-00406-CR Frelin Orellana, *2 Leonard Storemski, Hugo Pachas-Luna, 01-14-00516-CR, et. seq. 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.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable

Court grants this requested hold on the briefing schedule until after such time as the

reporter’s record is correctly filed – or, alternatively, grant an extension of time to file

the Appellant’s brief in the above cause and extend the time for filing Appellant’s brief

by 30 days, to February 12, 2015.

Respectfully Submitted, LEXANDER UNIN Chief Public Defender Harris County, Texas 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 *3 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.

Sarah V. Wood