Markle, Lesle ( 2015 )

PD-0287-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
April 23, 2015 Transmitted 4/22/2015 4:32:24 PM
Accepted 4/23/2015 10:13:52 AM
NO. PD-0287-15 ABEL ACOSTA
CLERK
TO THE COURT OF CRIMINAL APPEALS
No. 01-13-01028-CR
LESLE MARKLE
Appeal from Cause Number 1865367
From the County Criminal Court No. 12
Harris County
vs.
THE STATE OF TEXAS
APPELLANT’S FINAL MOTION FOR EXTENSION
FILED CONCURRENTLY WITH PDR
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, LESLE MARKLE, and files this Motion to Extend Time to File PDR, and
in support thereof, would respectfully show the Court the following:
I.
The First Court of Appeals affirmed the trial court’s judgment in an opinion styled
Markle v. State, 01-13-01028-CR, 2015 WL 505194 (Tex. App.—Houston [1st Dist.]
Feb. 5, 2015, no. pet. One other motion for extension has been granted.
II.
In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for
extension is timely filed within 15 days of the original deadline for the PDR, which
was April 8, 2015. Appellant requests this extension due to the fact that counsel for
Appellant has recently been ill for a protracted period of time, along with counsel’s
husband and child as well. This has interrupted counsel’s work schedule as she has
additionally 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 retrial in cause #1403196
 Vincent William, #1420283
 Darryle Robertson, 14-15-00132-CR
 Rodney Robins, 01-14-00582-CR
 Craig Beal, 01-12-00896-CR
 Abner Washington, 01-14-00885-CR
 Forest Penton, 14-14-00406-CR
 Leonard Storemski, 14-14-00920-CR
 Felix Irizarry, 14-14-00827-CR
 Eddie Aldape, 14-14-00996-CR
 Counsel has been researching and writing for several trial cases assigned to the
Public Defender’s Office Trial Division.
III.
Appellee’s attorney requests this extension of 14 days, which is necessary so that the
PDR can be thoroughly written and timely filed. This motion is not made for the
purpose of delay.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Honorable Court
grants this requested extension of time to file the PDR in the above cause and extend
the time for filing to April 22, 2015, the date of e-filing, or whatever date the filing is
officiated.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County, Texas
/s/ Sarah V. Wood
SARAH V. WOOD
Assistant Public Defender
Harris County, Texas
Texas Bar Number 24048898
1201 Franklin, 13th Floor
Houston Texas 77002
713.368.0016 (phone)
713.368.9278 (fax)
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 Appellant’s Final Motion to Extend Time to File PDR has been served via
the efile service on the Harris County District Attorney’s Office.
/s/ Sarah V. Wood
Sarah V. Wood