PD-0172-15
PD-0172-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 2/12/2015 11:05:05 AM
Accepted 2/12/2015 1:52:41 PM
TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA
CLERK
No. 01-13-00373-CR
NORMA CLARK
Appeal from Cause Number 1295757
From the 228th District Court
Harris County
vs.
THE STATE OF TEXAS
APPELLANT’S MOTION TO EXTEND TIME TO FILE PDR
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, NORMA CLARK, and files this Motion to Extend Time to File PDR, and
in support thereof, would respectfully show the Court the following:
I.
The First Court of Appeals affirmed the trial court’s judgment in an opinion dated
January 13, 2015. Clark v. State, 01-13-00373-CR, 2015 WL 162257 (Tex. App.—
Houston [1st Dist.] Jan. 13, 2015, no. pet. h.). No other motions for extension have
been filed.
II.
Appellant requests this extension due to the fact that counsel for Appellant has been
engaged in work in the Harris County Public Defender’s Office on many cases,
including the following:
In re K.C., 2012-04759J
Curtis Fournier, WR-82,102-01
Christopher Dowden, WR-82,103-01
February 12, 2015
Rodney Robins, 01-14-00582-CR
Craig Beal, 01-12-00896-CR
Abner Washington, 01-14-00885-CR
Forest Penton, 14-14-00406-CR
Felix Irizarry, 14-14-00827-CR
Dozens of writs of habeas corpus regarding the online solicitation of a minor
act being declared unconstitutional
Counsel has been researching and writing for several trial cases assigned to the
Public Defender’s Office Trial Division.
III.
Appellee’s attorney requests an 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, Appellee prays that this Honorable Court
grants this requested extension of time to file the PDR in the above cause and extend
the time for filing to March 14, 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 Appellant’s Motion to Extend Time to File PDR has been served via the
efile service on the Harris County District Attorney’s Office.
/s/ Sarah V. Wood
Sarah V. Wood
Clark, Norma Jean
Combined Opinion