ACCEPTED
14-15-00339-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
8/28/2015 5:19:48 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FOURTEENTH DISTRICT COURT OF APPEALS
HOUSTON, TEXAS FILED IN
NO. 14-15-00339-CR 14th COURT OF APPEALS
HOUSTON, TEXAS
PETE RODRIGUEZ 8/28/2015 5:19:48 PM
APPELLANT On Appeal from Cause Number 1978340
CHRISTOPHER A. PRINE
From the County Criminal Court #9
Clerk
Harris County, Texas
V.
THE STATE OF TEXAS
APPELLEE
APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF
APPEALS:
COMES NOW, Pete Rodriguez, 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 August 17, 2015. There have been
two previous motions for extension of time to file Appellant’s Brief.
II.
Counsel requests this extension because she been out of the office for an extended time
on family business and for health reasons and is struggling to catch up with a large
workload. Additionally, 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 rehearing in cause #1403196
Felix Irizarry, 14-14-00827-CR
Darryle Robertson, 14-15-00132-CR
Domingo Medina, 01-15-00575-CR
Ajah Foster, PD-0963-15
Frelin Orellana, 14-14-00701-CR
Kori Henegar, 14-15-00529-CR
Jesus Escobar, PD-0642-15
Stephen Hopper, 14-15-00371-CR
Craig Beal, 01-12-00896-CR
Forest Penton, 14-14-00406-CR
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 to September 28, 2015.
Respectfully Submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County, Texas
/s/ Sarah V. Wood
SARAH V. WOOD
Assistant Public Defender
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