PD-0403-15
COURT OF CRIMINAL APPEALS
April 15, 2015
PD-0403-15 AUSTIN, TEXAS
Transmitted 4/9/2015 11:01:38 AM
Accepted 4/15/2015 2:46:17 PM
ABEL ACOSTA
IN THE COURT OF CRIMINAL APPEALS CLERK
OF THE STATE OF TEXAS
NO. _________
JAIRO UMANZOR
Appellant,
On Appeal from the
V. 228TH District Court of
Harris County, Texas;
Trial Cause Number 1349385
THE STATE OF TEXAS
PETITIONER'S MOTION TO EXTEND TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF SAID COURT:
JAIRO UMANZOR, Petitioner in the above cause number, would respectfully
request this Court to grant his motion to extend the time to file his petition for
discretionary review. In support of said motion, Mr. Umanzor would show unto the
Court the following:
I.
This appeal lies from Mr. Umanzor’s conviction in The State of Texas v. Jairo
Umanzor, Cause Number 1349385 in the 228th District Court of Harris County, Texas.
Mr. Umanzor was charged by indictment with murder. Mr. Umanzor was convicted
by a jury and sentenced by the jury to fifteen (15) years in the Institutional Division of
the Department of Criminal Justice. Mr. Umanzor’s conviction was affirmed on
March 26, 2015, by the Fourteenth Court of Appeals in Cause No. 14-13-00958-CR.
Mr. Umanzor’s Petition for Discretionary Review is due April 27, 2015. This is Mr.
Umanzor’s first request for an extension to file the petition for discretionary review.
II.
Mr. Umanzor’s attorney of record, Daucie Schindler, is requesting an extension
of time in order to further evaluate the complex issues involved in the case. An
extension of time is necessary so that the petition for discretionary review can be
timely filed and undersigned counsel can properly consult with Mr. Umanzor. This
motion is not made for the purpose of delay.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this
Honorable Court will grant this requested extension of time to file the Appellant's
Petition for Discretionary Review in the above cause for thirty days and extend the
time for filing the petition until May 27, 2015.
Respectfully submitted,
Alexander Bunin
Chief Public Defender
/s/ Daucie Schindler
Daucie Schindler
State Bar No. 24013495
Harris County
Public Defender’s Office
Assistant Public Defender
1201 Franklin 13th Floor
Houston, Texas 77002
Daucie.Schindler@pdo.hctx.net
Tel: 713-368-0016
Fax: 713-368-9278
CERTIFICATE OF SERVICE
I do hereby certify that a copy of the foregoing instrument was this day
electronically served on counsel for the State and by mailing same to the following
parties on this the 9th day of April, 2015:
Ms. Abbie Miles
Harris County District Attorney's Office
Appellate Division
1201 Franklin, Suite 600
Houston, Texas 77002
State Prosecuting Attorney
P.O. Box 12405
Austin, Texas 78711
/s/ Daucie Schindler
Daucie Schindler