PD-0096-15
PD-0096-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 1/22/2015 3:52:50 PM
January 28, 2015
Accepted 1/28/2015 10:48:27 AM
IN THE COURT OF CRIMINAL APPEALS ABEL ACOSTA
CLERK
OF THE STATE OF TEXAS
PD-___________________
MICHAEL JERMAINE WILLIAMS, §
Appellant § On Petition for Review of
v. § No. 14-13-00527-CR
§ Court of Appeals
§ Fourteenth District of Texas
THE STATE OF TEXAS §
Appellee
PETITIONER/APPELLANT’S MOTION TO EXTEND TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
Petitioner/Appellant Michael Jermaine Williams moves for an extension of
time to file his petition for discretionary review, under TEX. R. APP. P. 10.5(b).
I. LOWER COURT PROCEEDINGS
Judgment in this case was entered on June 7, 2013. The court of appeals
affirmed on December 23, 2014. No motion for rehearing was filed.
II. PROCEEDINGS IN THIS COURT
Mr. Williams’s petition is due on January 22, 2014. No previous extensions
have been requested.
III. REASONS FOR REQUEST
The 30 days since the court of appeals’ opinion included the Christmas holiday,
when counsel was vacationing with her family out of state. Further, since counsel’s
return, counsel has missed more than a week of work with the flu.
Also in the last 30 days, counsel provided legal research and argument in a
murder trial in Harris County District Court. Finally, counsel also has been working to
complete a brief in the case of Reginald Turon Hill v. State, Cause No. 14-14-00376-CR,
which has no further extensions and is past-due.
III. FILING OF MOTION
In the exercise of due diligence, counsel could not complete Mr. Williams’s
petition by the deadline. This motion is not filed for purposes of delay, but so justice
may be done.
PRAYER
Mr. Williams respectfully requests that this motion be granted and that the
Court permit an extension of time until February 23, 2015, to file his petition for
discretionary review.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Cheri Duncan
______________________________
CHERI DUNCAN
Assistant Public Defender
Harris County Texas
State Bar No. 06210500
1201 Franklin, 13th Floor
2
Houston Texas 77002
(713) 368-0016
(713) 368-9278 (Fax)
cheri.duncan@pdo.hctx.net
Attorney for Petitioner/Appellant,
MICHAEL JERMAINE WILLIAMS
CERTIFICATE OF SERVICE
I certify that a copy of Appellant’s Motion to Extend Time to File Appellate
Brief was served on the State of Texas by electronic delivery to the Appellate Division
of the Harris County District Attorney’s Office and the State Prosecuting Attorney,
on January 22, 2015.
/s/ Cheri Duncan
_________________________
CHERI DUNCAN
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