PD-1671-15
PD-1671-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/28/2015 12:00:00 AM
Accepted 12/28/2015 1:26:45 PM
ABEL ACOSTA
IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK
AUSTIN, TEXAS
CARLTON CHARLES PENRIGHT §
§
VS . § CASE NO.
§
THE STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
NOW COMES, the appellant, Carlton Charles Penright, by and through his
assistant public defender Jani Maselli Wood, and respectfully moves the Court to grant
an additional thirty days to file the petition for discretionary review and for god cause
would show:
I.
Mr. Penright was convicted of sexual assault. He was sentenced to 15 years in
prison. The Court of appeals affirmed his case in a published opinion on September 29,
2015. Penright v. State, 01-12-00647-CR, 2015 WL 5770006 (Tex. App.—Houston [1st
Dist.] Sept. 29, 2015, no. pet. h.). A motion for reconsideration en banc was timely filed
and denied on December 8, 2015. Justice Jennings dissented to the denial of rehearing.
II.
The petition is due on January 7, 2016. Mr. Penright is requesting an additional
thirty days to prepare the petition until February 7, 2016.
December 28, 2015
III.
Undersigned counsel’s reason for the request is:
12/26/2015 - Brief filed in Rigoberto Monrroy v. State, 01-15-00644-CR
12/17/2015 - Reply brief filed in Carl Lovings v. State, 14-15-00167-CR
12/14/2015 - PDR filed in Ryan Stairhime v. State,
12/12/2015 - Brief filed in Chauncey Seymour v. State, 14-15-00636-CR
12/11/2015 - Cert. petition filed in U.S. Supreme Court in Osmin Peraza v. State of
Texas, 15-7367
12/9/2015 - Brief filed in Derek Washington v. State, 14-15-00558, 00559-CR
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that
this Court grant an additional 30 days for the petition for discretionary review.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Jani Maselli Wood
_______________________
JANI J. MASELLI WOOD
Assistant Public Defender
State Bar Number 00791195
Harris County Texas
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0001
(713) 368-9278 (Fax)
Jani.Maselli@pdo.hctx.net
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Attorney for Appellant,
Carlton Charles Penright
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on December 26, 2015, a
copy of the foregoing was emailed to the Harris County District Attorney’s Office and
emailed to counsel for the state and the State Prosecuting Attorney’s Office (through
texfile.com) at the following address:
Jessica Akins
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
akins_jessica@dao.hctx.net
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
/s/ Jani J Maselli Wood
___________________________________
JANI J. MASELLI WOOD
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