Mario Dunn v. State ( 2015 )

ACCEPTED
14-14-00340-cr
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/23/2015 3:06:26 PM
CHRISTOPHER PRINE
CLERK
IN THE
FOURTEENTH COURT OF APPEALS
OF TEXAS
MARIO DUNN § FILED IN
14th COURT OF APPEALS
§ HOUSTON, TEXAS
VS. § Case Number No. 14-15-00340-CR
7/23/2015 3:06:26 PM
§ CHRISTOPHER A. PRINE
THE STATE OF TEXAS § Clerk
Second Motion to Extend Time to File Brief
Now comes Mario Dunn, appellant in the above-styled and numbered cause, by
and through assistant public defender, Jani J. Maselli Wood, and respectfully moves
the Court for an extension of time within which to file the appellate brief, and for
cause would show the Court as follows:
I.
On March 24, 2015, Mr. Dunn was convicted of violating a protective order
and sentenced to 120 days in the Harris County Jail in Cause Number 1920929 in the
County Criminal Court at law Number 9 of Harris County, Texas, styled The State of
Texas v. Mario Dunn.
II.
The brief is currently due July 27, 2015. One previous extension was requested
and received.
III.
Undersigned counsel is requesting 30 days from the current due date until
August 26, 2015.
IV.
Briefs/Rehearings/PDR’s filed:
7/23/2015 - Motion for Rehearing to CCA in Peraza v. State, PD 0100-15, 0101-15;
7/15/2015 - Brief in Shaun Briggs v. State, 01-15-00269-CR;
7/14/2013 - PDR in Gregorio Guerrero v. State, PD 0665-15, 0666-15;
7/13/2015 - PDR in Kenneth McAfee v. State, PD 0667-15;
7/2/2015 - Reply brief filed in Mary Kuol v. State, 14-14-01008-CR;
6/28/2015 - Brief filed in Marcus Lewis v. State, 14-14-00779-CR;
6/2/2015 - Brief filed in Mary Kuol v. State, 14-14-01008-CR;
5/28/2015 - Brief filed in Joe Lee Bowden v. State, 14-14-00955-CR
Briefs Due
8/2/2015 - Brief due after PDR grant in CCA in London v. State, PD 480-15;
CLE Attended
6/16-20, 2015 - TCDLA Rusty Duncan Criminal Law Course
7/8-11, 2015 - TCDLA seminar in South Padre
V.
This request is made not to delay the proceedings, but to ensure that Mr. Dunn is
adequately represented.
WHEREFORE, PREMISES CONSIDERED, Mr. Dunn respectfully prays
that the Court permit an extension of time until August 26, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Jani Maselli 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,
Mario Dunn
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on July 23, 2015, a copy of
the foregoing was emailed to counsel for the state (through texfile.com) at the
following address:
Alan Curry
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
curry_alan@dao.hctx.net
/s/ Jani J Maselli Wood
___________________________________
JANI J. MASELLI WOOD