Roach, Chance ( 2015 )

PD-0643-15
PD-0643-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
May 28, 2015 Transmitted 5/27/2015 6:37:48 PM
Accepted 5/28/2015 4:20:08 PM
TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA
CLERK
FROM THE FIRST COURT OF APPEALS
NO. 01–14–00392–CR
CHANCE ROACH
APPELLANT On Appeal from Cause Number 1394753
From the 185th District Court of Harris County
V.
THE STATE OF TEXAS
APPELLEE
APPELLANT’S FIRST MOTION TO EXTEND TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, CHANCE ROACH, and files this his Motion to Extend Time to File Petition for
Discretionary Review, and in support thereof, would respectfully show the Court the
following:
I.
The First Court of Appeals affirmed the trial court’s judgment in Roach v. State, 01-14-00392-
CR, 2015 WL 1778896 (Tex. App.—Houston [1st Dist.] Apr. 16, 2015, no. pet. h.). No motion
for rehearing was filed. No other motions for extension have been filed.
II.
In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for extension is
timely filed within 15 days of the original deadline for the PDR, which was May 18, 2015.
Appellant requests this extension due to the fact that counsel for Appellant has been engaged
in work in the Harris County Public Defender’s Office on many cases, including the following:
 Rodney Robins, 01-14-00582-CR
 Stephen Hopper, 14-15-00371-CR
 Pete Rodriguez, 14-15-00339-CR
 Vincent Williams, 14-15-00220-CR
 Darryle Robertson, 14-15-00132-CR
 Leonard Storemski, 14-14-00921-CR
 Counsel has been researching and writing for several trial cases assigned to the Public
Defender’s Office Trial Division.
III.
Appellant’s attorney requests this brief extension which is necessary so that the petition can
be thoroughly written and timely filed. This motion is not made for the purpose of delay.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court grants this
requested extension of time to file the appellant’s petition for discretionary review in the above
cause and extend the time for filing for 30 days, to June 27, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County, Texas
/s/Sarah V. Wood
SARAH V. WOOD
Assistant Public Defender
Harris County, Texas
Texas Bar Number 24048898
1201 Franklin, 13th Floor
Houston Texas 77002
713.368.0016 (phone)
713.368.9278 (fax)
Sarah.Wood@pdo.hctx.net
Attorney for Appellant
CERTIFICATE OF SERVICE
By my signature below, I hereby certify that a true and correct copy of the above and foregoing
Appellant’s Motion to Extend Time to File Petition for Discretionary Review has been served
on the District Attorney of Harris County, Texas, by electronic delivery through the efile
system.
/s/Sarah V. Wood
Sarah V. Wood
Attorney for Appellant