ACCEPTED
01-14-00582-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/12/2015 9:11:15 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FIRST DISTRICT COURT OF APPEALS
HOUSTON, TEXAS FILED IN
NO. 01-14-00582-CR 1st COURT OF APPEALS
HOUSTON, TEXAS
1/12/2015 9:11:15 AM
RODNEY ROBINS
CHRISTOPHER A. PRINE
APPELLANT On Appeal from Cause Number 1408007
Clerk
From the 179th District Court
Harris County, Texas
V.
THE STATE OF TEXAS
APPELLEE
APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS:
COMES NOW, Rodney Robins, 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 January 2, 2015. There has been one
previous motion for extension of time to file Appellant’s Brief.
II.
Appellant requests this extension due to the fact that counsel has been engaged in work
in the Harris County Public Defender’s Office on many cases, including the following:
Curtis Fournier, WR-82,102-01 – briefing ordered in Court of Criminal Appeals
Christopher Dowden, WR-82,103-01– briefing ordered in Court of Criminal
Appeals
Craig Beal, 01-12-00896-CR
Abner Washington, 01-14-00885-CR
Forest Penton, 14-14-00406-CR
Frelin Orellana, 14-14-00701-CR
Leonard Storemski, 14-14-00920-CR
Hugo Pachas-Luna, 01-14-00516-CR, et. seq.
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 requested hold on the briefing schedule until after such time as the
reporter’s record is correctly filed – or, alternatively, grant an extension of time to file
the Appellant’s brief in the above cause and extend the time for filing Appellant’s brief
by 30 days, to February 12, 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
Phone: (713) 368-0016
Fax: (713) 368-9278
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 has been served upon the Harris County District Attorney's Office – Alan
Curry, via the electronic filing service.
/s/ Sarah V. Wood
Sarah V. Wood
Rodney Wayne Robins v. State
Combined Opinion