Gonzalez, Jesus

PD-0119-15 PD-0119-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS February 4, 2015 Transmitted 1/30/2015 1:51:10 PM Accepted 2/4/2015 10:09:06 AM PD-_____________ ABEL ACOSTA CLERK JESUS GONZALEZ X IN THE COURT OF CRIMINAL APPEALS X X VS. X X X THE STATE OF TEXAS X OF THE STATE OF TEXAS MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW COMES NOW, JESUS GONZALEZ, Appellant, and moves that he be granted a thirty (30) day extension of time to file his Petition for Discretionary Review in the above-styled and numbered cause, until and including February 18, 2015, and further shows as follows: A. The Appellant’s conviction for intoxication manslaughter was affirmed by the First Court of Appeals on December 18, 2014, in cause number 01-12-01115-CR; B. The original deadline for filing the Appellant’s P.D.R. in this cause was January 18, 2015, which made it due on January 20, 2015; C. A request is hereby made for an extension of time to file the Appellant’s P.D.R., until and including February 18, 2015; D. The reason for this extension request is that the undersigned attorney has been extremely busy with other appeals and various other matters which have left him unable to finish the PDR on time, including, but not limited to, the following: 1) Alfred Rodriguez, Jr. v. The State of Texas; No. 01-14-00394-CR; Appellant’s brief due February 2, 2015; 2) Khalon Westbrooks v. The State of Texas; Nos. 14-14-00499-CR &14-14- 00500-CR; Appellant’s brief due February 2, 2015; 3) William Horhn v. State of Texas; Nos. 01-14-00738-CR & 01-14-00739-CR; Appellant’s brief due February 2, 2015; 4) Jose Vasquez v. State of Texas; No. 14-12-00096-CR; Response to a State’s Petition for Discretionary Review due February 5, 2015; 5) Joseph Jackson v. State of Texas; No. 14-15-00017-Cr; Appellant’s brief due February 25, 2015. E. No previous extensions have been granted. If this extension is granted, the PDR will be filed by February 18, 2015, and no further extensions will be required. WHEREFORE, PREMISES CONSIDERED, Appellant moves that the Court extend the deadline for filing the Appellant’s Petition for Discretionary Review in this case until and including February 18, 2015. Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas /s Mark Kratovil MARK C. KRATOVIL Assistant Public Defender Harris County Texas 1201 Franklin, 13th Floor Houston Texas 77002 (713)274-6728 TBA No. 24076098 CERTIFICATE OF SERVICE A true copy of this motion has been hand delivered to the appellate division of the Harris County District Attorney’s Office on January 30, 2015. /s Mark Kratovil MARK C. KRATOVIL