PD-0206-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 3/24/2015 10:06:58 AM
Accepted 3/25/2015 2:41:58 PM
PD-0206-15 ABELAJP|TA
CLERK
JAMIE ALBERTO IBARRA X IN THE COURT OF CRIMINAL APPEALS
X
vs. x ^X^+°
x 4^1*
THE STATE OF TEXAS x
X OF THE STATE OF TEXAS SV
^L_
MOTION FOR ONE-WEEK EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
COMES NOW, JAMIE ALBERTO IBARRA, Appellant, and moves for an
extension of seven (7) days in which to file his Petition for Discretionary Review, until
and including April 1, 2015, and would further show as follows:
A. On January 22, 2015, in cause number 14-13-00337-CR, styled 'Jamie Alberto
Ibarra vs. The State of Texas," the Fourteenth Court of Appeals affirmed the
Appellant's conviction for aggravated assault on a public servant. No motion
for rehearing was filed.
B. The deadline for filing the Petition for Discretionary Review in this cause is
currently Wednesday, March 23, 2015.
C. A request is hereby made for an extension of time to file the Appellant's Brief,
until and including April 1, 2015.
D. The undersigned attorney, Bob Wicoff, has been unusually busy with other
matters which have kept him from completing the PDR by the current
deadline, including, but notlimited to, the following: C0URT OF CRIMINALAPPEALS
March 25, 2015
ABEL ACOSTA, CLERK
FEANYICHI UVUKANSI VS. THE STATE OF TEXAS; No. 01-14-00527-
CR; Appellant's brief filed March 9, 2015 (capital murder-56-page brief);
GRISELDA AZA VS. THE STATE OF TEXAS; Nos. 14-14-00241 -CR and
14_14_00242-CR; Appellant's brief filed March 11, 2015;
RICHARD ANTHONY SCOTT VS. THE STATE OF TEXAS; No. 14-14-
00726-CR; Appellant's brief filed March 18, 2015, 2015;
NORMA SANCHEZ VS. THE STATE OF TEXAS; No. 01-14-00978-CR;
Appellant's brief filed March 19, 2015;
Additionally, the undersigned serves on the Texas Forensic Science
Commission Hair Microscopy Panel, as part of a team reviewing hundreds of cases
involving possible errors in expert testimony. The Panel meets this Friday, March 27,
2015, at the Texas Department of Public Safety headquarters in Austin, and in
preparation for such meeting, the undersigned must complete a survey of hundreds
of old homicide and murder cases to determine the status of such convictions. This
project takes a lot of time.
Finally, the undersigned also has ongoing administrative duties in his position
as chief of the appellate division of the Harris County Public Defender's Office.
D. One previous extension has been granted. No further extensions will be
needed.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Bob Wicoff
BOB WICOFF
1201 Franklin, Thirteenth Floor
Houston Texas 77002
(713) 274-6781
TBA No. 21422700
Bob.wicoff@pdo.hctx.net
CERTIFICATE OF SERVICE
A true copy of this motion has been served electronically on the Harris County
District Attorney's Office Appellate Division on the 24th day of March, 2015.
/s/ Bob Wicoff
BOB WICOFF