PD-0761-15
PD-0761-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/23/2015 11:08:13 AM
Accepted 6/24/2015 11:23:01 AM
NO. ______________ ABEL ACOSTA
CLERK
IN THE COURT OF CRIMINAL APPEALS OF TEXAS
PATRICK MARCEL BROWN
Appellant
v.
THE STATE OF TEXAS
Appellee
On PDR from Cause No. 14-13-00839-CR in the Fourteenth Court of Appeals,
Affirming Cause No. 1382169 in the 262nd District Court of Harris County, Texas
MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY
REVIEW
TO THE HONORABLE COURT:
Nicolas Hughes, appellate counsel for Patrick Brown, files this Motion for
Extension of Time to File Petition for Discretionary Review. In support of the
motion, Appellant would state the following:
A. Appellant filed an appeal in the Fourteenth Court of Appeals in Houston.
B. Appellant’s case was numbered and styled as follows: Patrick Marcel Brown v.
State of Texas, No. 14-13-00839-CR (Tex. App.−Houston [14th Dist.], opinion
May 28, 2015)
June 24, 2015
C. On May 28, 2015, the Fourteenth Court of Appeals affirmed Appellant’s
conviction.
D. The petition for discretionary review is due in this case on June 27, 2015.
E. Appellant is seeking an extension of time to file PDR, as he does not anticipate
having adequate time to properly prepare his petition for discretionary review.
F. No previous extension has been requested.
G. Counsel has been out of the office for the majority of last month, including
from May 20 – May 27 (Counsel’s wedding), from June 6 – June 12 (National
Forensic College for Defenders), and from June 16 – June 20 (Public Defender
Training and Rusty Duncan Seminar)
H. Additionally, Counsel has been working on the following cases / projects
a. Briefing ordered in Ex parte Michael Williams, No. WR-82,970-01 (Tex.
Crim. App., filed June 22, 2015).
b. Appellate Brief in Lamb v. State, No. 01-14-00901-CR (Tex.
App.−Houston [1st. Dist.], filed May 29, 2015).
c. State v. John Enard, Nos. 1375416, 1439251, 1453912 (178th Dist. Ct.,
Harris County, Tex., filed Jan 19, 2013). (civil commitment litigation
involving complex constitutional issues).
d. Various writs of habeas corpus drafted in response to drug lab results
which conflict with Harris County convictions.
I. Appellant seeks an extension of time pursuant to TEX. R. APP. P. 68.2 until July
27, 2015.
WHEREFORE, Appellant would ask that this court would grant his request to
extend time allowed for him to file his petition for discretionary review by 30 days
(July 27, 2015).
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Nicolas Hughes
NICOLAS HUGHES
Assistant Public Defender
Harris County Texas
1201 Franklin Street, 13th Floor
Houston Texas 77002
(713) 368-0016
(713) 386-9278 fax
TBA No. 24059981
nicolas.hughes@pdo.hctx.net
CERTIFICATE OF SERVICE
I certify that a copy of this Motion for Extension of Time to File Petition for
Discretionary Review has been served upon the Harris County District Attorney's
Office -— Appellate Section and to the State Prosecuting Attorney, on July 27, 2015
by electronic service.
/s/ Nicolas Hughes
NICOLAS HUGHES