Smith, Carl Lee ( 2015 )

PD-0795-15
PD-0795-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/29/2015 12:00:00 AM
Accepted 6/29/2015 4:14:54 PM
ABEL ACOSTA
IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK
AUSTIN, TEXAS
CARL SMITH §
§
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, Carl Lee Smith, 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. Smith was convicted of capital murder and sentenced to life without parole.
His conviction was affirmed on June 16, 2015 in an unpublished opinion in Cause
Number 14-13-00595-CR.
II.
The petitions is due July 16, 2015. Mr. Smith is requesting an additional thirty
days to prepare the petition until August 15, 2015
.
June 29, 2015 III.
Undersigned counsel has numerous deadlines in the next thirty days and has been
working diligently to handle all her cases:
Filed Cases
Brief for Joe Bowden v. State, 14-14-00955-CR filed on May 28, 2015;
Brief filed in Mary Kuol v. State, 14-14-01008-CR filed on June 2, 2015
Brief filed in Marcus Jamez Lewis v. State, 14-14-00779-CR on June 28, 2015
PDR’s due (NFE because of previous extensions)
Gregorio Guerrero v. State, due 7/15/2015;
Kenneth McAfee v. State, due 7/13/2015
Briefs due:
Brief after PDR granted due in Joshua London v. State, due July 24, 2015
Lawrence Glover v. State, 14-15-00082-CR - due July 13, 2015
Shaun Briggs v. State, 01-15-00269-CR - due July 15, 2015
Carl Lovings v. State, 14-15-00167-CR - due on July 19, 2015
Mario Dunn v. State, 14-15-00340-CR - due on July 27, 2015
CLE
Counsel is the course director and will be attending Train the Trainers and a CDLP
training in South Padre Island from July 7-11, 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,
Carl Lee Smith
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on June 28, 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
/s/ Jani J. Maselli Wood
___________________________________
JANI J. MASELLI WOOD
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