Hill, Reginald Turon

PD-1260-15 PD-1260-15
COURT OF CRIMINAL APPEALS
November 2, 2015
AUSTIN, TEXAS
Transmitted 11/2/2015 2:22:35 PM
Accepted 11/2/2015 3:47:33 PM
IN THE COURT OF CRIMINAL APPEALS ABEL ACOSTA
CLERK
OF THE STATE OF TEXAS
PD-1260-15
REGINALD TURON HILL §
Appellant § On Petition for Review of
v. § No. 14-14-00376-CR
§ Court of Appeals
§ Fourteenth District of Texas
THE STATE OF TEXAS §
Appellee
APPELLANT’S MOTION
TO EXTEND TIME TO FILE PETITION
Appellant Reginald Turon Hill for an extension of time to file his petition for
discretionary review, under TEX. R. APP. P. 10.5(b).
I. LOWER COURT PROCEEDINGS
Judgment in this case was entered on May 8, 2014. The court of appeals affirmed
on August 25, 2015. No motion for rehearing was filed.
II. PROCEEDINGS IN THIS COURT
Mr. Hill’s petition was due on October 26, 2015 after the Court granted a
previous extension. Counsel has filed the petition today, November 2, 2015.
III. REASONS FOR REQUEST
Mr. Hill’s counsel was unable to complete the petition in the last 30 days because
counsel: 1) briefed, prepared, and argued opposition to a motion for waiver of
jurisdiction hearing in juvenile court for an appellate client whose conviction was
reversed in light of Moon v. State (the hearing was today, November 2, 2015); 2) filed a
brief in Margaret Renee Mayer v. State, Cause No. 14-14-01011-CR, which had been
abated; 3) filed a brief in Eric Samuel Tucker v. State, Cause No. 01-15-00274-CR; and 4)
is working to complete two other briefs in the next two weeks. In the exercise of due
diligence, counsel could not timely complete this petition.
PRAYER
Mr. Hill respectfully requests that this motion be granted and that the Court
permit an extension of time until November 2, 2015 to file his Petition for Discretionary
Review.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Cheri Duncan
______________________________
CHERI DUNCAN
Assistant Public Defender
Harris County Texas
State Bar No. 06210500
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0016
(713) 368-9278 (Fax)
cheri.duncan@pdo.hctx.net
Attorney for Petitioner/Appellant,
REGINALD TURON HILL
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CERTIFICATE OF SERVICE
I certify that a copy of Appellant’s Motion to Extend Time to File Petition for
Discretionary Review was served on the State of Texas by electronic delivery to the
Appellate Division of the Harris County District Attorney’s Office and the State
Prosecuting Attorney, on November 2, 2015.
/s/ Cheri Duncan
_________________________
CHERI DUNCAN
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