PD-0172-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
March 25, 2015 Transmitted 3/23/2015 9:02:51 AM
Accepted 3/25/2015 10:53:40 AM
NO. PD-0172-15 ABEL ACOSTA
CLERK
TO THE COURT OF CRIMINAL APPEALS
No. 01-13-00373-CR
NORMA CLARK
Appeal from Cause Number 1295757
From the 228th District Court
Harris County
vs.
THE STATE OF TEXAS
APPELLANT’S FINAL MOTION FOR EXTENSION
FOR 4 DAYS
WITH PDR ALREADY FILED
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, NORMA CLARK, and files this Final Motion to Extend Time to File
PDR, and in support thereof, would respectfully show the Court the following:
I.
The First Court of Appeals affirmed the trial court’s judgment in an opinion dated
January 13, 2015. Clark v. State, 01-13-00373-CR, 2015 WL 162257 (Tex. App.—
Houston [1st Dist.] Jan. 13, 2015, no. pet. h.). One motion for extension was granted
and the PDR was due on March 16, 2015. The PDR was filed on March 20, 2015.
II.
Counsel humbly requests this extension due to the fact that counsel suffers from a
chronic painful condition that has recently caused a disruption in counsel’s work
schedule and slightly delayed the filing of the PDR in this important and complex
case.
Additionally, counsel has been engaged in work in the Harris County Public
Defender’s Office on many cases, including the following:
Lenin Lopez, 01-13-01079-CR, reversed and set for retrial in cause #1403196
Vincent William, #1420283
Darryle Robertson, 14-15-00132-CR
Rodney Robins, 01-14-00582-CR
Craig Beal, 01-12-00896-CR
Abner Washington, 01-14-00885-CR
Forest Penton, 14-14-00406-CR
Leonard Storemski, 14-14-00920-CR
Felix Irizarry, 14-14-00827-CR
Eddie Aldape, 14-14-00996-CR
Leslie Markle, 01-13-01028-CR
Counsel has been researching and writing for several trial cases assigned to the
Public Defender’s Office Trial Division.
III.
Appellant’s attorney requests an extension of 4 days, 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 extension of time to file the PDR in the above cause and extend
the time for filing to the date PDR was filed or March 20, 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
713.368.0016 (phone)
713.368.9278 (fax)
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 Appellant’s Motion to Extend Time to File PDR has been served via the
efile service on the Harris County District Attorney’s Office.
/s/ Sarah V. Wood
Sarah V. Wood