Mary Kuol v. State ( 2015 )

ACCEPTED
14-14-01008-cr
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
5/6/2015 12:46:35 PM
CHRISTOPHER PRINE
CLERK
IN THE
FOURTEENTH COURT OF APPEALS
OF TEXAS
FILED IN
14th COURT OF APPEALS
MARY KUOL § HOUSTON, TEXAS
§ 5/6/2015 12:46:35 PM
VS. § Case Number No. 14-14-01008-CR
CHRISTOPHER A. PRINE
§ Clerk
THE STATE OF TEXAS §
First Motion to Extend Time to File Brief
Now comes Mary Kuol, 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 December 8, 2014, Ms. Kuol was convicted of the offense of
prostitution and sentenced to three years imprisonment in the Texas Department of
Criminal Justice - Institutional Division. She was convicted in cause number
1314040 in the 248th District Court of Harris County, Texas, styled The State of
Texas v. Mary Kuol.
II.
The brief is currently due May 7, 2015. No extensions have been requested.
III.
Undersigned counsel is requesting 30 days from the current due date until
June 7, 2015.
IV.
Counsel has been working on a murder appeal in State v. Joe Lee Bowden. The
record is lengthy;
On April 30, 2015, counsel filed a PDR in State v. Joshua London;
On March 25, 2015, the Court of Criminal Appeals granted the State’s PDR
in Osmin Peraza v. State, NOS. PD-0100 & PD-0101-15. The CCA ordered expedited
briefing (15 days per side with no extensions of time permitted). Undersigned
counsel filed the brief on April 23, 2015. The CCA then set argument for May 20,
2015. This is also requiring additional time to prepare for argument.
V.
This request is made not to delay the proceedings, but to ensure that Ms. Kuol is
adequately represented.
WHEREFORE, PREMISES CONSIDERED, Ms. Kuol respectfully prays
that this undersigned counsel be designated as the attorney of record in this cause
and that the Court permit an extension of time until June 7, 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,
Mary Kuol
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on May 6, 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