WR-82, 102-01
COURT OF CRIMINAL APPEALS
FILED IN AUSTIN, TEXAS
COURT OF CRIMINALAPPEALS Transmitted 1/2/2015 1:19:59 PM
January 2 2015 Accepted 1/2/2015 1:25:03 PM
TO THE COURT OF CRIMINAL APPEALS ABEL A£°?™
ABEL ACOSTA, CLERK CLERK
WR-82, 102-01
Ex Parte
On Application for a Writ of Habeas Corpus
Cause Number 1151921 in the ^o
351st District Court from Harris County ^C^P
Curtis Fournier Vj l%
Applicant's Motion To Extend Time
To File Brief i>
To The Honorable Judges Of The Court Of Criminal Appeals:
Comes Now, Curtis Fournier, and files this his Motion to Extend Time to File
Brief, and in support thereof, would respectfully show the Court the following:
I.
This Court ordered briefing in this case from both parties to be due on December 30,
2014. No previous extensions have been requested.
II.
Applicant's attorney requests this extension because in this past month, counsel has
suffered a very unpleasant and lingering virus and counsel's child has also been ill,
which has disrupted counsel's work schedule in addition to holiday obligations and
counsel's work on many cases including a trial setting on December 23, 2014. Counsel
has also been working on the following matters:
• In re K. C, Juvenile Trial Court No. 2012-04759J
• Craig Beat, 01-12-00S96-CR
• Abner Washington, 01-14-00885-CR
• Forest Penton, 14-14-00406-CR
• Rodney Robins, Q\-\4-W5%2-CR
• Hugo Pachas-Luna, 01-14-00516-CR, et. seq.
III.
Appellee's attorney requests this extension of 30 days, 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, Applicant prays that this Honorable Court
grants this requested extension of time to file the brief in the above cause and extend
the time for filing to January 30, 2015.
Respectfully submitted,
Alexander Bunin
Chief Public Defender
Harris County, Texas
/ S/ c^ata* t/. (/(/&&Fournier, Curtis
Combined Opinion