Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 6/22/2015 2:15:51 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00920-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/22/2015 2:15:51 PM 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 OS . 14-14-00920-CR, 14-14-00921-CR
L EONARK S TOREMSKI
A PPELLANT On Appeal from Cause Nos. 1361696, 1361698
From the 263 rd District Court, Harris County
V.
T HE S TATE OF T EXAS
A PPELLEE
Appellant’s FINAL Motion For Extension
For 10 Days
Due to Exceptional Circumstances TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF APPEALS:
COMES NOW, Leonard Storemski, and files this Final 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 May 27, 2015. There have been two
previous motions for extension of time to file Appellant’s Brief.
II.
Counsel for the appellant had intended to have filed the brief in this case by now but must
humbly request this extension due to the fact that counsel has recently suffered unanticipated
interruptions in her work schedule due to family illnesses and the flooding and its attendant
damage. Additionally, counsel 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
Chance Roach, PD-0643-15
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 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 extension of time to file the Appellant’s brief in the above cause and
extend the time for filing Appellant’s brief by 10 days, to July 2, 2015.
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
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