ACCEPTED
14-14-00701-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
3/3/2015 9:14:56 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FOURTEENTH DISTRICT COURT OF APPEALS
HOUSTON, TEXAS FILED IN
NO. 14-14-00701-CR 14th COURT OF APPEALS
HOUSTON, TEXAS
FRELIN ORELLANA 3/3/2015 9:14:56 AM
APPELLANT On Appeal from Cause Number 1397962
CHRISTOPHER A. PRINE
th
From the 177 District Court Clerk
Harris County, Texas
V.
THE STATE OF TEXAS
APPELLEE
APPELLANT’S FINAL MOTION FOR EXTENSION
FOR 14 DAYS
DUE TO EXCEPTIONAL CIRCUMSTANCES
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF
APPEALS:
COMES NOW, Frelin Orellana, 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 March 2, 2015. There have been
three previous motions for extension of time to file Appellant’s Brief.
II.
Counsel apologizes for the delay and humbly requests this final extension of fourteen
days. Counsel had expected the brief in this case to have been completed at this time.
However, counsel has recently experienced a disruption in her work schedule due to a
painful chronic illness. Additionally, counsel’s child was ill which resulted in further
delay. Further, 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 retrial in cause #1403196
Vincent William, #1420283
Darryle Robertson, 14-15-00132-CR
Rodney Robins, 01-14-00582-CR
Craig Beal, 01-12-00896-CR
Abner Washington, 01-14-00885-CR
Forest Penton, 14-14-00406-CR
Leonard Storemski, 14-14-00920-CR
Norma Clark, PD-0172-15
Felix Irizarry, 14-14-00827-CR
Eddie Aldape, 14-14-00996-CR
Leslie Markle, 01-13-01028-CR
Dozens of writs of habeas corpus regarding the online solicitation of a minor
act being declared unconstitutional
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 of the time for filing Appellant’s brief and extends the
deadline by 14 days, to March 17, 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
Frelin Danilo Orellano v. State
Combined Opinion