PD-1593-15 PD-1593-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/7/2015 2:26:02 PM
Accepted 12/7/2015 3:44:37 PM
ABEL ACOSTA
IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK
AUSTIN, TEXAS
SHAUN DEVILLE BRIGGS §
§
VS . § CASE NO.
§
THE STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
NOW COMES, the appellant, Shaun Deville Briggs, by and through his assistant
public defender Jani Maselli Wood, and respectfully moves the Court to grant an
additional thirty days to file the petition for discretionary review and for god cause would
show:
I.
Mr. Briggs was convicted of aggravated robbery with a deadly weapon. He was
sentenced to 15 years in prison. The Court of appeals affirmed his case in an
unpublished opinion on November 10, 2015. Shaun Deville Briggs v. State, 2015 WL
6935565, 01-15-00269-CR (Tex. App. – Houston [1st Dist.] November 10, 2015, no pet.
h.).
II.
The petition is due on December 10, 2015. Mr. Briggs is requesting an additional
thirty days to prepare the petition until January 9, 2016.
December 7, 2015
III.
Undersigned counsel’s reason for the request is:
Hearings:
November 17 & 19, 2015 - Hearing on Motion for New Trial in Herman Whitfield v. State
Filings and Oral Arguments:
11/10/2015 - PDR filed in Jimmy Earl Van-Cleave v. State, PD 1253-15
10/28/2015 - Oral argument in Marcus Jamez Lewis v. State, 14-14-00779-CR
10/26/2015 - PDR filed in William Johnson v. State, 1254-15
10/22/2015 - Oral argument in Mary Kuol v. State, 14-14-01008-CR
10/19/2015 - Motion for Reconsideration en banc filed in Carlton Penright v. State, 01-12-
00647-CR
10/16/2015 - Motion for new trial filed in Herman Whitfield v. State, Cause Number
1424070
Personal
Counsel had a medical procedure and missed work on December 3-4, 2015.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that
this Court grant an additional 30 days for the petition for discretionary review.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
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Harris County Texas
/s/ Jani Maselli Wood
_______________________
JANI J. MASELLI WOOD
Assistant Public Defender
State Bar Number 00791195
Harris County Texas
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0001
(713) 368-9278 (Fax)
Jani.Maselli@pdo.hctx.net
Attorney for Appellant,
Shaun Deville Briggs
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on December 7, 2015, a copy
of the foregoing was emailed to the Harris County District Attorney’s Office and
emailed to counsel for the state and the State Prosecuting Attorney’s Office (through
texfile.com) at the following address:
Kimberly Stelter
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
stelter_kimberly@dao.hctx.net
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
/s/ Jani J Maselli Wood
___________________________________
JANI J. MASELLI WOOD
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