Miranda, Adrian Francisco

PD-0827-15 PD-0827-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/2/2015 11:56:07 AM Accepted 7/2/2015 4:10:58 PM No. _____________ ABEL ACOSTA CLERK In the Court of Criminal Appeals At Austin  No. 14-14-00091-CR In the Court of Appeals for the Fourteenth District of Texas at Houston  No. 1400039 In the 185th District Court Harris County, Texas  ADRIAN FRANCISCO MIRANDA Appellant V. THE STATE OF TEXAS Appellee  APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE PETITION FOR DISCRETIONARY REVIEW  July 2, 2015 TO THE HONORABLE COURT OF APPEALS: APPELLANT, pursuant to TEX. R. APP. P. 68.2(c) moves for an extension of time within which to file its petition for discretionary review. In support of its motion, appellant submits the following: 1. Appellant was charged with the felony offense of aggravated sexual assault of a child. 2. A jury convicted appellant of the charged offenses and the court sentenced him to 25 years confinement in the Institutional Division of the Texas Department of Criminal Justice on January 16, 2014. 3. A unanimous panel of the Fourteenth Court of Appeals rendered judgment in an unpublished opinion on April 23, 2015, affirming appellant’s conviction and sentence. 4. Appellant filed a Motion for Rehearing and Motion for En Banc Reconsideration. Both were denied on June 2, 2015. 5. Appellant’s petition for discretionary review is due on July 2, 2015. 6. Appellant seeks an extension, in accordance with TEX. R. APP. P. 68.2(c), until August 3, 2015, to file a petition for discretionary review. 7. The following facts are relied upon to show good cause for the requested extension: a. Counsel has been working on the appellate briefs in Dorsey v. State, No. 01-14-00685-CR., Hayes v. State, 04-14-00878-CR. and 04-14- 00879-CR., and Ross v. State, 01-14-00902-CR. b. Counsel filed a petition for discretionary review in Campuzano v. State, No. PD-0476-15 and No. PD-0477-15. c. Counsel has filed a writ of certiorari in the United States Supreme Court in Masterson v. Stephens. d. Appellant’s petition is not for purposes of delay, but so that justice may be done. 2 WHEREFORE, the Appellant prays that this Court will grant the requested extension until August 3, 2015. Respectfully submitted, /s/MANDY MILLER Attorney for appellant 2910 Commercial Center Blvd., Ste. 103-201 Katy, TX 77494 SBN 24055561 PHONE (832) 900-9884 FAX (877) 904-6846 mandy@mandymillerlegal.com CERTIFICATE OF SERVICE Pursuant to TEX. R. APP. P. 9.5, this certifies that on July 2, 2015, a copy of the foregoing was delivered to the following addresses: Alan Curry Harris County District Attorney’s Office curry_alan@dao.hctx.net Lisa McMinn State Prosecuting Attorney lisa.mcminn@spa.state.tx.us /S/MANDY MILLER 3