PD-0665-15 & PD-0666-15
PD-0665&0666-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/1/2015 12:25:08 PM
Accepted 6/1/2015 3:50:59 PM
ABEL ACOSTA
IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK
AUSTIN, TEXAS
GREGORIO GUERRERO §
§
VS. § CASE NOS.
§
THE STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
NOW COMES, the appellant, Gregorio Guerrero, by and through his attorney
Jani J. Maselli Wood, and respectfully moves the Court to grant an additional thirty days
to file the petitions for discretionary review and for good cause would show:
I.
Mr. Guerrero was convicted of aggravated robbery with a deadly weapon and
evading arrest. In two identical unpublished opinions, his convictions were affirmed
May 14, 2015 in Cause Numbers 01-13-00821-CR and 01-13-00822-CR.
II.
The petitions are due on June 13, 2015. Mr. Guerrero is requesting an additional
thirty days to prepare the petition until July 13, 2013.
III.
Undersigned counsel has numerous deadlines in the next thirty days and has been
working diligently to handle all her cases:
June 1, 2015
Filed Cases
Brief for Joe Bowden v. State, 14-14-00955-CR filed on May 28, 2015;
PDR in Joshua London v. State, PD 0480-15 filed on May 1, 2015;
Oral Argument
Oral argument at the CCA in Osmin Peraza v. State on May 20, 2015
Briefs due:
Mary Kuol v. State, 14-14-01008-CR - due June 8, 2015
Lawrence Glover v. State, 14-15-00082-CR - due June 11, 2015
Shaun Briggs v. State, 01-15-00269-CR - due June 15, 2015
Carl Lovings v. State, 14-15-00167-CR - due on June 19, 2015
Mario Dunn v. State, 14-15-00340-CR - due on June 26, 2015
CLE
Counsel will be attending Public Defender Training and the TCDLA Rusty Duncan
Seminar from June 17-20, 2015
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that
this Court grant an additional 30 days to file the petition for discretionary review.
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Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Jani J. Maselli Wood
___________________________________
JANI J. MASELLI WOOD
State Bar No. 00791195
1201 Franklin Street, 13th Floor
Houston, TX 77002
(713) 274-6721
Attorney for Appellant,
Gregorio Guerrero
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on June 1, 2015, a copy of
the foregoing was emailed to Lisa McMinn, State Prosecuting Attorney, and the Harris
County District Attorney’s Office through texfile.com at the following address:
Carly Dessauer
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
Dessauer_carly@dao.hctx.net
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
/s/ Jani J. Maselli Wood
___________________________________
JANI J. MASELLI WOOD
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