Pachas-Luna, Hugo D. ( 2015 )

PD-1537&1538&1539&1540&1541-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/24/2015 1:05:23 PM Accepted 11/25/2015 10:53:41 AM TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA CLERK From the First Court of Appeals Nos. 01-14-00516-CR, 01-14-00517-CR, 01-14-00518-CR, 01-14-00519-CR, 01-14-00520-CR HUGO PACHAS-LUNA On Appeal from Cause Numbers 1370904, 1370905, 1370906, 1370907, 1370908 vs. From the 230th District Court Harris County, Texas STATE OF TEXAS Motion to Extend Time to File PDR TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: COMES NOW, HUGO PACHAS-LUNA, and files this his Motion to Extend Time to File PDR, and in support thereof, would respectfully show the Court the following: I. The First Court of Appeals affirmed the trial court’s judgment of guilt on October 15, 2015. Appellant’s PDR was due on November 15, 2015. No previous motions for extension have been filed. II. In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for extension is filed within 15 days of the deadline for the PDR. Counsel requests this extension primarily due to a heavy workload and has been engaged in work in the Harris County Public Defender’s Office on many cases, include the following:  Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196  Joseph Smith, 14-15-00625-CR  Darryle Robertson, 14-15-00132-CR  Michael Davila, 01-15-00560-CR November 25, 2015  Stephen Hopper, 14-15-00371-CR  Domingo Medina, 01-15-00575-CR  Kori Henegar, 14-15-00529-CR  Craig Beal, 01-12-00896-CR  Corey Nickerson, 01-15-00764-CR through 01-15-00766-CR  Emanuel Hayes, 1408364  Research and writing in preparation for several cases for the trial division of the Harris County Public Defender’s Office. IV. Appellant’s attorney requests an extension of 30 days 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 30 days to file the appellant’s PDR in the above cause and extend the time for filing to December 24, 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 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 Brief on the Merits has been served on the State Prosecuting Attorney and the District Attorney of Harris County, Texas, via the e-file service. /s/Sarah V. Wood