Hankston, Gareic Jerard ( 2015 )

PD-0887-15 COURT OF CRIMINAL APPEALS PD-0887-15 AUSTIN, TEXAS Transmitted 7/16/2015 12:59:57 PM July 17, 2015 Accepted 7/17/2015 2:55:53 PM ABEL ACOSTA CLERK NO. ______________ IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS GAREIC JERALD HANKSTON Trial Court Number Appellant 1326559 178th District Court Harris County, Texas V. Court of Appeals Number THE STATE OF TEXAS 14-13-00923-CR MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT: GAREIC HANKSTON Appellant, respectfully requests that the Court grant his motion to extend time to file his petition for discretionary review. In support of said motion, Appellant would show unto the Court the following: I. Appellant’s conviction was affirmed on June 16, 2015 by the Fourteenth Court of Appeals in Cause No. 14-13-00923-CR. Appellant’s Petition for Discretionary Review is due July 16, 2015. This is Appellant's first request for an extension to file the petitions for discretionary review. II. Counsel will not be able to file the Petition for Discretionary Review as she has been working on the following cases in the last thirty days: 1. Counsel has been helping in the trial preparation in State of Texas v. Derek Boone, Cause Number 1416801 in the 228th District Court of Harris County. The case was set for trial on June 22, 2015. 2. Counsel was preparing for oral argument in State of Texas v. Issac Smith, Cause Number 14-14-00139-CR which was held on June 17, 2015. 3. Counsel has been investigating possible Motions for New Trial in three new cases: a. State of Texas v. Willie Clarke, Cause Numbers 1453864, 1457279 and 1465671 in the 178th District Court of Harris County. The deadline for filing a Motion for New Trial was June 27, 2015. b. State of Texas v. Lawson Echieto, Cause Number 2017593 in the County Court at Law No. 9 of Harris County. The deadline for filing a Motion for New Trial was July 9, 2015. c. State of Texas v. Troy Evans, Cause Number 1423548 in the 174th District Court of Harris County. The deadline for filing a Motion for New Trial is July 24, 2015. VI. An extension of time is necessary so that the petition can be timely filed. This motion is not made for the purpose of delay. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court will grant this requested extension of time to file the Appellant's Petition for Discretionary Review in the above cause and extend the time for filing the petition for at least thirty (30) days. Respectfully submitted, Alexander Bunin Chief Public Defender /s/ Angela Cameron Angela Cameron State Bar No. 00788672 Harris County Public Defender’s Office 1201 Franklin 13th Floor Houston, Texas 77002 Tel: 713-368-0016 angela.cameron@pdo.hctx.net CERTIFICATE OF SERVICE I certify that on the 16th day of July 2015 a copy of the foregoing instrument has been electronically served upon the State of Texas. /s/ Angela Cameron Angela Cameron