Clark, Norma Jean

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