Leonard Mark Storemski v. State

ACCEPTED 14-14-00920-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/22/2015 2:15:51 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT COURT OF APPEALS HOUSTON, TEXAS FILED IN NOS. 14-14-00920-CR, 14-14-00921-CR 14th COURT OF APPEALS LEONARK STOREMSKI HOUSTON, TEXAS APPELLANT 6/22/2015 On Appeal from Cause Nos. 2:15:51 1361696, PM 1361698 CHRISTOPHER A. From the 263 District Court, Harris County rd PRINE Clerk V. THE STATE OF TEXAS APPELLEE Appellant’s FINAL Motion For Extension For 10 Days Due to Exceptional Circumstances TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF APPEALS: COMES NOW, Leonard Storemski, and files this Final Motion to Extend Time to File Brief, and in support thereof, would respectfully show the Court the following: I. The current deadline for filing Appellant’s Brief is May 27, 2015. There have been two previous motions for extension of time to file Appellant’s Brief. II. Counsel for the appellant had intended to have filed the brief in this case by now but must humbly request this extension due to the fact that counsel has recently suffered unanticipated interruptions in her work schedule due to family illnesses and the flooding and its attendant damage. Additionally, counsel has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:  Ruben Totten, PD-0483-15  Bobby Easley, PD-0468-15  Chance Roach, PD-0643-15  Hugo Pachas-Luna, 01-14-00516-CR - 01-14-00520-CR  Rodney Robins, 01-14-00582-CR  Stephen Hopper, 14-15-00371-CR  Pete Rodriguez, 14-15-00339-CR  Vincent Williams, 14-15-00220-CR  Darryle Robertson, 14-15-00132-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 this extension 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 Appellant’s brief in the above cause and extend the time for filing Appellant’s brief by 10 days, to July 2, 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 Phone: (713) 368-0016 Fax: (713) 368-9278 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 has been served upon the Harris County District Attorney's Office – Alan Curry, via the electronic filing service. /s/ Sarah V. Wood Sarah V. Wood