Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 8/28/2015 5:19:48 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00339-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/28/2015 5:19:48 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 O .
P ETE R ODRIGUEZ
A PPELLANT On Appeal from Cause Number 1978340
From the County Criminal Court #9
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 FOURTEENTH COURT OF
APPEALS:
COMES NOW, Pete Rodriguez, 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 August 17, 2015. There have been
two previous motions for extension of time to file Appellant’s Brief.
II.
Counsel requests this extension because she been out of the office for an extended time
on family business and for health reasons and is struggling to catch up with a large
workload. Additionally, counsel has been engaged in work in the Harris County Public
Defender’s Office on many cases, including the following: Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196 Felix Irizarry, Darryle Robertson, Domingo Medina,
Ajah Foster, PD-0963-15
Frelin Orellana, 14-14-00701-CR
Kori Henegar,
Jesus Escobar, PD-0642-15 Stephen Hopper, Craig Beal, Forest Penton, 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 extension to September 28, 2015.
Respectfully Submitted, LEXANDER UNIN Chief Public Defender ARAH V. W OOD Assistant Public Defender 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 *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