PD-0206-15 PD-0206-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
February 26, 2015 Transmitted 2/20/2015 1:01:33 PM
Accepted 2/26/2015 8:50:55 AM
PD- ABEL ACOSTA
CLERK
JAMIE ALBERTO IBARRA 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, JAMIE ALBERTO IBARRA, Appellant, and moves for an
extension of thirty (30) days in which to file his Petition for Discretionary Review,
until and including March 23, 2015, and would further show as follows:
A. On January 22, 2015, in cause number 14-13-00337-CR, styled “Jamie Alberto
Ibarra vs. The State of Texas,” the Fourteenth Court of Appeals affirmed the
Appellant’s conviction for aggravated assault on a public servant. No motion
for rehearing was filed.
B. The deadline for filing the Petition for Discretionary Review in this cause is
currently Monday, February 23, 2015.
C. A request is hereby made for an extension of time to file the Appellant’s Brief,
until and including March 23, 2015.
D. The undersigned attorney, Bob Wicoff, has been unusually busy with other
matters which have kept him from completing the PDR by the current
deadline, including, but not limited to, the following:
FEANYICHI UVUKANSI VS. THE STATE OF TEXAS; No. 01-14-00527-
CR; Appellant’s brief due March 6, 2015 (capital murder);
MARCUS BORTLE VS. THE STATE OF TEXAS; No. 01-14-00978-CR;
Appellant’s brief was due February 19, 2015;
GRISELDA AZA VS. THE STATE OF TEXAS; Nos. 14-14-00241-CR and
14-14-00242-CR; Appellant’s brief due February 25, 2015;
NORMA SANCHEZ VS. THE STATE OF TEXAS; No. 01-14-00978-CR;
Appellant’s brief due February 27, 2015;
Additionally, the undersigned serves on the Texas Forensic Science
Commission Hair Microscopy Panel, as part of a team reviewing hundreds of cases
involving possible errors in expert testimony. The undersigned also has ongoing
administrative duties in his position as chief of the appellate division of the Harris
County Public Defender’s Office.
D. No previous extensions have been requested. If this extension request is
granted, no further extensions are expected to be needed.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Bob Wicoff__________
BOB WICOFF
1201 Franklin, Thirteenth Floor
Houston Texas 77002
(713) 274-6781
TBA No. 21422700
Bob.wicoff@pdo.hctx.net
CERTIFICATE OF SERVICE
A true copy of this motion has been served electronically on the Harris County
District Attorney’s Office Appellate Division on the 20th day of February, 2015.
/s/_Bob Wicoff_________
BOB WICOFF