Totten, Ruben ( 2015 )

PD-0483-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/22/2015 1:26:56 PM
Accepted 6/24/2015 10:07:50 AM
NO. PD-0483-15 ABEL ACOSTA
CLERK
TO THE COURT OF CRIMINAL APPEALS
FROM THE FIRST COURT OF APPEALS
NO. 01-14-00189-CR
RUBEN TOTTEN
APPELLANT On Appeal from Cause Number 1365961
From the 228th District Court, Harris County
V.
THE STATE OF TEXAS
APPELLEE
Appellant’s Motion To Extend Time
To File Reply to State’s Petition For Discretionary Review
Filed with Reply
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, RUBEN TOTTEN, and files this his Motion to Extend Time to File Reply to
State’s Petition for Discretionary Review, and in support thereof, would respectfully show the
Court the following:
I.
The First Court of Appeals reversed the trial court’s judgment in Totten v. State, 01-14-00189-
CR, 2015 WL 1501799 (Tex. App.—Houston [1st Dist.] Mar. 31, 2015). The State filed a
petition for discretionary review on June 1, 2015.
II.
In compliance with Texas Rule of Appellate Procedure 68.2(c), 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:
 Hugo Pachas-Luna, 01-14-00516-CR - 01-14-00520-CR
 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 June 24, 2015
 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 6 days, to June 22, 2015, the date of filing the reply.
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