Wood, Dean Jerome ( 2014 )

PD-1659-14
PD-1659-14 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/19/2014 1:20:04 PM
December 29, 2014 Accepted 12/29/2014 10:06:31 AM
PD- ABEL ACOSTA
CLERK
DEAN JEROME WOOD X IN THE COURT OF CRIMINAL APPEALS
X
X
VS. X
X
X
THE STATE OF TEXAS X OF THE STATE OF TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
COMES NOW, DEAN JEROME WOOD, Appellant, and moves that he be
granted a thirty (30) day extension of time to file his Petition for Discretionary
Review, until and including January 5, 2015, and further shows as follows:
A. The Appellant’s conviction for murder was affirmed by the First Court of
Appeals in cause number 01-13-00845-CR on November 6, 2014.
B. The deadline for filing the Appellant’s P.D.R. in these causes was December
6, 2014 (thereby making them due on Monday, December 8, 2014). This request for
extension of time is being e-filed on December 19, 2014, which is within the 15-day
period provided for by Tex. R. App. P. 68.2(c).
C. A request is hereby made for an extension of time to file the Appellant’s
P.D.R. in this case, until and including January 5, 2015.
D. The reason for this extension request is that the undersigned attorney has
been extremely busy with other appeals and various other matters which have left him
unable to finish the PDR on time, including, but not limited to, the following:
FEANYICHI UVUKANSI VS. THE STATE OF TEXAS; No. 01-14-00527-
CR; Appellant’s Brief due on January 7, 2014 (capital murder);
RICHARD SCOTT VS. THE STATE OF TEXAS; No. 01-12-00643-CR;
Appellant’s Brief due on January 7, 2015;
NORMA SANCHEZ VS. THE STATE OF TEXAS; No. 14-14-00780-CR;
Appellant’s Brief due December 29, 2014.
Additionally, the undersigned is extremely busy with his duties as chief of the
appellate division of the Harris County Public Defender’s Office, as a member of the
Texas Forensic Science Commission Hair Microscopy Panel (which is in the process
of reviewing hundreds of criminal cases involving expert testimony in cases involving
hair testimony), and, as an adjunct professor at the University of Houston Law
Center, is under a December 23rd deadline to get numerous final exams and term
papers graded.
E. No further extensions will be needed.
WHEREFORE, PREMISES CONSIDERED, Appellant moves that the Court
extend the deadline for filing the Appellant’s Petition for Discretionary Review in
these cases, until and including January 5, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Bob Wicoff
BOB WICOFF
Assistant Public Defender
Harris County Texas
1310 Prairie, Ste. 980
Houston Texas 77002
(713) 274-6781
TBA No. 21422700
CERTIFICATE OF SERVICE
A true copy of this motion has been sent through the e-file system to the
appellate division of the Harris County District Attorney’s Office, on the 19th of
December, 2014.
/s/ Bob Wicoff
BOB WICOFF