London, Joshua ( 2015 )

PD-0480-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/23/2015 11:15:06 AM
July 23, 2015 Accepted 7/23/2015 11:26:18 AM
IN THE TEXAS COURT OF CRIMINAL APPEALS ABEL ACOSTA
CLERK
AUSTIN, TEXAS
JOSHUA LONDON §
§
VS. § CASE NO. PD 480-15
§
THE STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
NOW COMES, the appellant, Joshua London, by and through his assistant public
defender Jani J. Maselli Wood, and respectfully moves the Court to grant an extension of time
to file the brief in this case and in support would show the Court the following:
I.
The petition for discretionary for review was filed with this Court on May 1, 2015.
Review was granted on June 24, 2015.
II.
The brief is due on July 24, 2015. Counsel is requesting an additional two weeks to finish
this brief, until August 7, 2015.
III.
The request is based upon the following:
Briefs/PDR’s filed:
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;
Motion for Rehearing Due
7/23/2015 - Motion for Rehearing to CCA in Peraza v. State, PD 0100-15, 0101-15;
IV.
This request is not made to delay the proceedings but to ensure London is effectively
represented.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that this
Court grant this motion and set a due date for Mr. London’s brief on August 7, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
Jani J Maselli Wood
___________________________________
JANI J. MASELLI WOOD
Assistant Public Defender
State Bar No. 00791195
1201 Franklin Street, 13th Floor
Houston, TX 77002
(713) 274-6721
Attorney for Appellant,
Joshua London
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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 Lisa McMinn, State Prosecuting Attorney, and the Harris
County District Attorney’s Office through texfile.com at the following address:
Eric Kugler
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
kugler_eric@dao.hctx.net
Lisa McMinn
Lisa.McMinn@SPA.texas.gov
Jani Maselli Wood
_________________________________
JANI J. MASELLI WOOD
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