Martinez, Luis Ruben Islas v. State

PD-0029-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 1/6/2015 9:45:27 PM Accepted 1/14/2015 4:33:56 PM ABEL ACOSTA NO. _____________ CLERK IN THE COURT OF CRIMINAL APPEALS OF TEXAS ________________ LUIS RUBEN ISLASMARTINEZ, Appellant/Petitioner VS. THE STATE OF TEXAS, Appellee/Respondent _____________________________________________________________ APPELLANT’S MOTION TO EXTEND THE TIME FOR FILING PETITION FOR DISCRETIONARY REVIEW _____________________________________________________________ Seeking discretionary review of a decision of the Court of Appeals for the Fifth District of Texas at Dallas in Appeal No. 05-13-00953-CR TO THE HONORABLE COURT OF CRIMINAL APPEALS: COMES NOW the Appellant/Petitioner and files this Motion to Extend the Time for Filing a Petition for Discretionary Review in the above-referenced case, and would show the following: 1 I. On June 6, 2013, the Appellant was convicted of aggravated sexual assault of a child younger than 14 years of age in Cause No. F13-00162-L in the Criminal District Court No. 5 of Dallas County, Texas, and sentenced to confinement for eight (8) years in TDCJ-ID. II. The Appellant timely filed notice of appeal, and the appeal was styled Luis Ruben Islas Martinez v. The State of Texas, Appeal No. 05-13-00953-CR, in the Dallas Court of Appeals. The Dallas Court of Appeals issued an opinion modifying the judgment and affirming the conviction on December 9, 2014. No motion for rehearing was filed. III. The current deadline for filing a Petition for Discretionary Review is Thursday, January 8, 2015. See TEX. R. APP. P. 68.2(a). The Appellant requests a 30-day extension of time to file the Petition for Discretionary Review until Monday, February 9, 2015. See TEX. R. APP. P. 4.1(a). IV. No prior extensions have been granted to the Appellant in this case. 2 V. The Appellant would show that a reasonable explanation exists for this requested extension of time: (1) In the past 30 days, the undersigned attorney has completed work on the following appeal briefs: 1. Valentin Carus v. The State of Texas, Appeal No. 05-14-00272-CR, prepared and then filed appellant’s brief in the Dallas Court of Appeals on December 8, 2014. 2. Cristal Paullett Richardson v. The State of Texas, Appeal No. 05-14- 00523-CR, prepared and then filed appellant’s brief in the Dallas Court of Appeals on December 17, 2014. 3. Miguel Gonzalez, Jr. v. The State of Texas, Appeal No. 05-14-00888-CR, prepared and then filed appellant’s brief in the Dallas Court of Appeals on December 31, 2014. (2) Moreover, the undersigned attorney, who was appointed to represent the Appellant on his direct appeal and for the Petition for Discretionary Review, just recently accepted an offer to return to work as the chief of the appellate division in the Dallas County District Attorney’s office. Another attorney, the Honorable Larry Mitchell, is being appointed to represent the Appellant in the filing of the Petition for Discretionary Review. Of course, new counsel will need adequate time to familiarize himself with the appellate record and the issues in the appeal. 3 WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully requests that the time for filing his Petition for Discretionary Review in this case be extended to Monday, February 9, 2015. Respectfully submitted, /s/ Lori L. Ordiway LORI L. ORDIWAY State Bar No. 12327300 P.O. Box 793991 Dallas, Texas 75379 Telephone: (972) 701-0155 Facsimile: (972) 701-0151 E-mail: lori.ordiway@att.net ATTORNEY FOR THE APPELLANT CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that a true and correct copy of this motion is being served on the 6th day of January, 2015, via the service function in eFile Texas, on: (1) the attorneys for the State of Texas, Patricia Poppoff Noble, Assistant District Attorney, Dallas County District Attorney’s Office, to pnoble@dallascounty.org, and the State Prosecuting Attorney, to information@spa.texas.gov, and (2) Larry Mitchell to judge.mitchell@gmail.com. /s/ Lori L. Ordiway LORI L. ORDIWAY 13-25 4