Johnson, William ( 2015 )

PD-1254-15
PD-1254-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 9/22/2015 7:59:36 AM
Accepted 9/24/2015 2:30:19 PM
ABEL ACOSTA
IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK
AUSTIN, TEXAS
WILLIAM JOHNSON §
§
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, William Johnson, by and through his assistant
public defender Jani J. Maselli Wood, and respectfully moves the Court to grant an
additional thirty days to file the petitions for discretionary review and for good cause
would show:
I.
Mr. Johnson was convicted of aggravated robbery with a deadly weapon and
sentenced to eight years imprisonment. His conviction was affirmed on August 25, 2015
in an unpublished opinion in Cause Number 14-14-00475-CR.
II.
The petitions is due September 24, 2015. Mr. Johnson is requesting an additional
thirty days to prepare the petition until October 24, 2015.
.
September 24, 2015
III.
Undersigned counsel has numerous deadlines in the next thirty days and has been
working diligently to handle all her cases:
Briefs filed:
Orlando Salinas v. State, brief on remand filled 9/7/2015;
Shaquille Ashton v. State, brief filed on 9/2/2015
Trial Setting
Counsel is set for trial in Jason Harrison v. State, in the 179th district court on
October 8, 2015. Pretrial conference was held September 10, 2015.
New Cases
Counsel has been appointed two very complicated cases in the last two weeks.
She is diligently working on a motion for new trial due on October 1, 2015.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that
this Court grant an additional 30 days to file the petition for discretionary review.
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Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Jani J. Maselli Wood
___________________________________
JANI J. MASELLI WOOD
State Bar No. 00791195
1201 Franklin Street, 13th Floor
Houston, TX 77002
(713) 274-6721
Attorney for Appellant,
William Johnson
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on September 22, 2015, a
copy of the foregoing was emailed to Lisa McMinn, State Prosecuting Attorney, and the
Harris County District Attorney’s Office through texfile.com at the following address:
Melissa Hervey
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
Hervey_Melissa@dao.hctx.net
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
/s/ Jani J. Maselli Wood
___________________________________
JANI J. MASELLI WOOD
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