Peraza, Osmin ( 2015 )

0101-15
FILED IN COURT OF CRIMINAL APPEALS
COURT OF CRIMINAL APPEALS AUSTIN, TEXAS
Transmitted 7/6/2015 12:00:00 AM
July 6, 2015 IN THE Accepted 7/6/2015 8:07:10 AM
ABEL ACOSTA
TEXAS COURT OF CLERK
ABELACOSTA, CLERK CRIMINAL APPEALS
OSMIN PERAZA
VS. § Case Numbers 0100-15 & 0101-15
THE STATE OF TEXAS
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Motion to Extend Time to File Motion for Rehearing i ^
Now comes Osmin Peraza, appellant in the above-styled and numbered causes,
by and through assistant public defender, Jani J. Maselli Wood, and respectfully
moves the Court for an extension of time within which to file his motion for
rehearing, and for cause would show the Court as follows:
I.
On July 1, 2015, this Court issued its opinions in the above-referenced case.
The cases reversed the lower court of appeals.
II.
The motion for rehearing is currently due July 16, 2015.
III.
Undersigned counsel is requesting 7 days from the current due date until July
23, 2015.
IV.
Undersigned counsel has numerous deadlines in the next thirty days and has
been working diligently to handle all her cases:
PDR's due (NFE because of previous extensions)
Gregorio Guerrero v. State, due 7/15/2015;
Kenneth McAfee v. State, due 7/13/2015
Briefs due:
Brief after PDR granted due in Joshua London v. State, due July 24, 2015
Shaun Briggs v. State, 01-15-00269-CR - due July 15, 2015
CarlLovings v. State, 14-15-00167-CR - due on July 19, 2015
Mario Dunn v. State, 14-15-00340-CR - due on July 27, 2015
CLE
Counsel is the course director and will be attending Train the Trainers and a CDLP
training in South Padre Island from July 7-11, 2015.
V.
This request is made not to delay the proceedings, but to ensure that Mr. Peraza
is adequately represented.
WHEREFORE, PREMISES CONSIDERED, Mr. Peraza respectfully prays
that this the Court permit an extension of time until July 23, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
Isi JaniMaselli 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,
Osmin Peraza
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on July 2, 2015, a copy
of the foregoing was emailed to counsel for the state (through texfile.com) at the
following address:
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
Isi JaniJMaselli Wood
JANI J. MASELLI WOOD