Campuzano, Jose Franco

PD-0477-15 PD-0477-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 4/29/2015 11:12:21 AM Accepted 4/29/2015 11:18:50 AM No. _____________ ABEL ACOSTA CLERK In the Court of Criminal Appeals At Austin  No. 01-13-00991-CR In the Court of Appeals for the First District of Texas at Houston  No. 1315240 In the 176th District Court Harris County, Texas  JOSE FRANCO CAMPUZANO Appellant V. THE STATE OF TEXAS Appellee  APPELLANT’S MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE PETITION FOR DISCRETIONARY REVIEW  April 29, 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 intoxication assault. 2. A jury convicted appellant of the charged offenses and sentenced him to 5 years community supervision on October 15, 2013. 3. A unanimous panel of the First Court of Appeals rendered judgment in an unpublished opinion on March 26, 2015, affirming appellant’s conviction and sentence. 5. Appellant’s petition for discretionary review was due April 27, 2015. 6. Appellant seeks an extension, in accordance with TEX. R. APP. P. 68.2(c), until May 27, 2015, to file its petition for discretionary review. This is appellant’s first request for an extension. 9. 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 Williams v. State, No. 01-14-00165-CR on April 29, 2015. 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 May 27, 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 April 29, 2015, a copy of the foregoing was delivered to the following addresses: Melissa Hervey Harris County District Attorney’s Office hervey_melissa@dao.hctx.net Lisa McMinn State Prosecuting Attorney lisa.mcminn@spa.state.tx.us /S/MANDY MILLER 3