WR-82, 102-01
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 1/2/2015 1:19:59 PM
January 2, 2015 Accepted 1/2/2015 1:25:03 PM
TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA
CLERK
WR-82, 102-01
EX PARTE
On Application for a Writ of Habeas Corpus
Cause Number 1151921 in the
351st District Court from Harris County
CURTIS FOURNIER
APPLICANT’S MOTION TO EXTEND TIME
TO FILE BRIEF
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, CURTIS FOURNIER, and files this his Motion to Extend Time to File
Brief, and in support thereof, would respectfully show the Court the following:
I.
This Court ordered briefing in this case from both parties to be due on December 30,
2014. No previous extensions have been requested.
II.
Applicant’s attorney requests this extension because in this past month, counsel has
suffered a very unpleasant and lingering virus and counsel’s child has also been ill,
which has disrupted counsel’s work schedule in addition to holiday obligations and
counsel’s work on many cases including a trial setting on December 23, 2014. Counsel
has also been working on the following matters:
In re K.C., Juvenile Trial Court No. 2012-04759J
Craig Beal, 01-12-00896-CR
Abner Washington, 01-14-00885-CR
Forest Penton, 14-14-00406-CR
Rodney Robins, 01-14-00582-CR
Hugo Pachas-Luna, 01-14-00516-CR, et. seq.
III.
Appellee’s attorney requests this extension of 30 days, 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, Applicant prays that this Honorable Court
grants this requested extension of time to file the brief in the above cause and extend
the time for filing to January 30, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County, Texas
/s/ Sarah V. Wood
SARAH V. WOOD
Assistant Public Defender
Harris County, Texas
Texas Bar Number 24048898
1201 Franklin, 13th Floor
Houston Texas 77002
713.368.0016 (phone)
713.368.9278 (fax)
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 Appellee’s Motion to Extend Time to File Brief has been served on Roe
Wilson, Assistant District Attorney of Harris County, Texas via the electronic e-file
system.
/s/Sarah V. Wood
Sarah V. Wood