PD-1591&1592-15 PD-1591&1592-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/7/2015 2:24:32 PM
Accepted 12/7/2015 3:34:36 PM
ABEL ACOSTA
IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK
AUSTIN, TEXAS
JOHNATHAN RENARD CASTANEDA §
§
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, Johnathan Renard Castaneda, 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. Castaneda was convicted of murder and aggravated sexual assault in two
separate cases. He was sentenced to a mandatory life sentence for the sexual assault case
and 45 years in prison for the murder. The Court of appeals affirmed both cases on
November 10, 2015, in one unpublished opinion. Johnathan Renard Castaneda v. State,
2015 WL 6930466, 01-14-00389-CR, 01-14-00390-CR (Tex. App. – Houston [1st Dist.]
November 10, 2015, no pet. h.).
December 7, 2015
II.
The petition is due on December 10, 2015. Mr. Castaneda is requesting an
additional thirty days to prepare the petition until January 9, 2016.
III.
Undersigned counsel’s reason for the request is:
Hearings:
November 17 & 19, 2015 - Hearing on Motion for New Trial in Herman Whitfield v. State
Filings and Oral Arguments:
11/10/2015 - PDR filed in Jimmy Earl Van-Cleave v. State, PD 1253-15
10/28/2015 - Oral argument in Marcus Jamez Lewis v. State, 14-14-00779-CR
10/26/2015 - PDR filed in William Johnson v. State, 1254-15
10/22/2015 - Oral argument in Mary Kuol v. State, 14-14-01008-CR
10/19/2015 - Motion for Reconsideration en banc filed in Carlton Penright v. State, 01-12-
00647-CR
10/16/2015 - Motion for new trial filed in Herman Whitfield v. State, Cause Number
1424070
Personal
Counsel had a medical procedure and missed work on December 3-4, 2015.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that
this Court grant an additional 30 days for the petition for discretionary review.
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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
Attorney for Appellant,
Johnathan Renard Castaneda
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CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on December 7, 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:
Eri Kugler
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
kugler_eric@dao.hctx.net
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
/s/ Jani J Maselli Wood
___________________________________
JANI J. MASELLI WOOD
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Castaneda, Johnathan Renard
Combined Opinion