Pete Hengoza Rodriguez v. State

ACCEPTED 14-15-00339-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/28/2015 5:19:48 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT COURT OF APPEALS HOUSTON, TEXAS FILED IN NO. 14-15-00339-CR 14th COURT OF APPEALS HOUSTON, TEXAS PETE RODRIGUEZ 8/28/2015 5:19:48 PM APPELLANT On Appeal from Cause Number 1978340 CHRISTOPHER A. PRINE From the County Criminal Court #9 Clerk Harris County, Texas V. THE STATE OF TEXAS APPELLEE APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF APPEALS: COMES NOW, Pete Rodriguez, and files this 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 August 17, 2015. There have been two previous motions for extension of time to file Appellant’s Brief. II. Counsel requests this extension because she been out of the office for an extended time on family business and for health reasons and is struggling to catch up with a large workload. Additionally, counsel has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:  Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196  Felix Irizarry, 14-14-00827-CR  Darryle Robertson, 14-15-00132-CR  Domingo Medina, 01-15-00575-CR  Ajah Foster, PD-0963-15  Frelin Orellana, 14-14-00701-CR  Kori Henegar, 14-15-00529-CR  Jesus Escobar, PD-0642-15  Stephen Hopper, 14-15-00371-CR  Craig Beal, 01-12-00896-CR  Forest Penton, 14-14-00406-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 extension to September 28, 2015. Respectfully Submitted, ALEXANDER BUNIN Chief Public Defender Harris County, Texas /s/ Sarah V. Wood SARAH V. WOOD Assistant Public Defender 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