Case Information

*1 PD-1593-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/7/2015 2:26:02 PM Accepted 12/7/2015 3:44:37 PM ABEL ACOSTA I N THE T EXAS C OURT OF C RIMINAL A PPEALS CLERK A USTIN , T EXAS S HAUN D EVILLE B RIGGS §

§ V S . § C ASE N O .

§ T HE TATE OF T EXAS §

M OTION FOR E XTENSION OF T IME T O THE H ONORABLE J UDGES OF THE OURT OF C RIMINAL A PPEALS

NOW COMES, the appellant, Shaun Deville Briggs, by and through his assistant public defender Jani Maselli Wood, and respectfully moves the Court to grant an additional thirty days to file the petition for discretionary review and for god cause would show:

I. Mr. Briggs was convicted of aggravated robbery with a deadly weapon. He was sentenced to 15 years in prison. The Court of appeals affirmed his case in an unpublished opinion on November 10, 2015. Shaun Deville Briggs v. State , 2015 WL 6935565, 01-15-00269-CR (Tex. App. – Houston [1st Dist.] November 10, 2015, no pet.

h.).

II. The petition is due on December 10, 2015. Mr. Briggs is requesting an additional thirty days to prepare the petition until January 9, 2016.

III.

Undersigned counsel’s reason for the request is:

Hearings :

November 17 & 19, 2015 - Hearing on Motion for New Trial in Herman Whitfield v. State Filings and Oral Arguments

11/10/2015 - PDR filed in Jimmy Earl Van-Cleave v. State , PD 1253-15

10/28/2015 - Oral argument in Marcus Jamez Lewis v. State , 14-14-00779-CR 10/26/2015 - PDR filed in William Johnson v. State , 1254-15

10/22/2015 - Oral argument in Mary Kuol v. State , 14-14-01008-CR

10/19/2015 - Motion for Reconsideration en banc filed in Carlton Penright v. State , 01-12- 00647-CR

10/16/2015 - Motion for new trial filed in Herman Whitfield v. State , Cause Number 1424070

Personal

Counsel had a medical procedure and missed work on December 3-4, 2015.

WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that this Court grant an additional 30 days for the petition for discretionary review.

Respectfully submitted, ALEXANDER BUNIN Chief Public Defender *3 Harris County Texas /s/ Jani Maselli Wood _______________________ JANI J. MASELLI WOOD Assistant Public Defender State Bar Number 00791195 Harris County Texas 1201 Franklin, 13th Floor Houston Texas 77002 (713) 368-0001 (713) 368-9278 (Fax) Jani.Maselli@pdo.hctx.net Attorney for Appellant, Shaun Deville Briggs ERTIFICATE OF ERVICE Pursuant to Tex. R. App. Proc. 9.5, this certifies that on December 7, 2015, a copy of the foregoing was emailed to the Harris County District Attorney’s Office and emailed to counsel for the state and the State Prosecuting Attorney’s Office (through texfile.com) at the following address:

Kimberly Stelter

Assistant District Attorney

1201 Franklin Street, 6th Floor

Houston, TX 77002

stelter_kimberly@dao.hctx.net

Lisa McMinn

Lisa.McMinn@SPA.texas.gov

/s/ Jani J Maselli Wood ___________________________________ JANI J. MASELLI WOOD